The Pennsylvania Supreme Court has held that plaintiff could recover for physical injuries resulting from fright and shock without showing a physical impact if plaintiff was in danger of physical impact because of the direction of a negligent force against him.
Niederman v. Brodsky, ___ Pa. ___ , 261 A.2d 84 (1970).
Frank M. McClellan,
Torts - Damages - "Impact Rule",
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol8/iss2/12