ABSTRACT
Courts use a variety of terms in their efforts to deal with Proximate Cause problems. One group of these problems has to do with the types of harm that occur in injury cases. Quite different from the economic loss problem is a specific category of personal injury—that is, emotional harm. A category of this kind is what is called economic loss, which in this area of law courts often distinguish from injury to person or tangible property. So strong has been judges' reliance on the "economic loss rule" that in a case where milking machines led to mastitis in the plaintiffs' cattle and a loss of milk production, the Michigan Supreme Court applied the rule. The duty/proximate cause problem arises in many guises: Different kinds of plaintiffs, odd ways in which accidents happen, remoteness of injuring events in time and space, different kinds of harm, intervening events and acts—for example, third party crimes.
