How have courts interpreted the impact rule in the context of intentional infliction of emotional distress?

Moreover, although the impact rule sought to narrow the scope of liability by reducing the number of fraudulent and speculative claims brought, even courts in jurisdictions following that rule have recognized that the mere existence of a physical injury does little to decrease the chance of fraud or the difficulty of the task faced by a jury in deciding whether emotional distress is present. See, e.g., Shuamber, 579 N.E.2d at 455 ("The mere fact of a physical injury, however minor, does not make mental distress damages any less speculative, subject to exaggeration, or likely to lead to fictitious claims . . . . [T]he presence or absence of some physical injury does nothing to alleviate the jury's burden in deciding whether the elements of mental suffering are present." (quoting Cullison v. Medley, 570 N.E.2d 27, 30 (Ind. 1991)) (internal quotation marks omitted)).

These failings have led courts to turn away from the traditional impact rule. An early exception to the doctrine developed in cases of intentional infliction of emotional distress. See, e.g., Price v. Yellow Pine Paper Mill Co., 240 S.W. 588, 594 (Tex. Civ. App. 1922)

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