the person, but only the feelings or reputation,” 41 Ark. at 298, and “which in their nature are invisible and intangible.” 110 Ark. at 138, 161 S.W. 136. The Estate’s suggestion to the contrary — that mental anguish and emotional distress constitute physical injuries to the person— is unpersuasive. Aside from the rather obvious distinction between physical and mental injuries drawn by the cases above, the Arkansas Supreme Court has long delineated between the two in the context of negligence liability. See Erwin v. Milligan, 188 Ark. 658, 663, 67 S.W.2d 592 (1934) (“The rule is well established that there can be no recovery for fright or mental pain and anguish caused by negligence, where there is no physical injury.”); Dowty v. Riggs, 2010 Ark. 465, at *6-*8, 385 S.W.3d 117 (2010) (<HOLDING>). Loss of employment compensation presents a
holding that arkansas does not recognize the tort of negligent infliction of emotional distress because the state does not permit damages based on mental suffering unaccompanied by physical injury holding that intentional infliction of emotional distress is a personal injury tort holding that the law does not recognize a cause of action for negligent infliction of emotional distress every time an employer negligently fails to comply with performance evaluation procedures resulting in an employees termination and emotional distress holding that employee could not state a claim for negligent infliction of emotional distress under fela without a showing of physical impact recognizing the tort of intentional infliction of emotional distress