February 26, 2026
Court of Appeal, Fourth Appellate District, Division One
The Rule of Fisher v. Fisher is that intentional infliction of emotional distress can be the legal cause of a wrongful death when the tortious conduct is a substantial factor in causing severe emotional distress that leads to the victim's death, under the broader scope of liability standard applicable to intentional torts rather than the narrower "scope of risk" standard used for negligence.