Special Topping At Burger King Causes Emotional Distress Absent Physical Injury.

Plaintiff brought an action for damages after he was served a hamburger at Burger King tainted with a glob of saliva later traced by DNA back to an employee. The district court dismissed because Washington law does not permit relief for emotional distress absent physical injury. The Ninth Circuit reversed the grant of summary judgment and remanded so plaintiff has an opportunity to amend.  Bylsma v. Burger King (Ninth Cir.;  February 12, 2013) (Case No. 10-36125)  [CCH Prod. Liab. Rep. P19,019].