Castro v. New York Life Insurance
Zoila Castro, a cleaning worker, sustained a hypodermic needle puncture wound to her right thumb while working at New York Life Insurance Co.'s offices on June 22, 1989. She subsequently developed a 'generalized anxiety disorder' and 'AIDS phobia' due to the incident, leading her and her husband, Osvaldo Castro, to file a personal injury action alleging negligence by New York Life for improper disposal of hazardous medical waste. New York Life moved to dismiss the complaint and for summary judgment, arguing that fear of AIDS without reasonable certainty is not compensable and that there was no medical evidence to support the claim. The court denied both of New York Life's motions, finding that Castro's claim for mental anguish and 'AIDS Phobia' was directly tied to the incident. It concluded that a reasonable person exposed to a discarded hypodermic needle could develop such a fear, thus guaranteeing the genuineness of her claim and necessitating a trial.