How have courts interpreted "bodily injury" in the context of personal injury?

California, United States of America


The following excerpt is from Chatton v. National Union Fire Ins. Co., 10 Cal.App.4th 846, 13 Cal.Rptr.2d 318 (Cal. App. 1992):

[10 Cal.App.4th 855] In Allstate Ins. Co. v. Diamant (1988) 401 Mass. 654, 518 N.E.2d 1154, 1156, the state court explained that "bodily injury" and "personal injury" are not synonymous notions. The term "personal injury" is broader and includes not only physical injury, but also affront or assault to the emotional well-being of a person. "Bodily injury," by comparison, is a narrow term which encompasses only physical injuries to the body and the consequences thereof. "Bodily injury" as commonly understood "imports harm arising from corporeal contact" and bodily refers to "an organism of flesh and blood" and is not satisfied by anything short of physical injury. In accordance therewith, the court held that the "bodily injury" does not include humiliation, mental anguish or suffering. (Id. 518 N.E.2d at p. 1157). In Presidential Hotel v. Canal Ins. Co. (Ga.App.1988) 373 S.E.2d 671,

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