Plaintiffs may not recover monetary damages for emotional distress suffered as a result of economic loss or the fear of future economic loss. In a negligence action, the United States District Court of Oregon refused to allow plaintiffs recovery for all emotional distress resulting from defendant's negligence in providing plaintiffs with a defective product which consequently resulted in economic loss.

The Carpenters were Oregon dairy farmers that ordered cow feed from Land 0' Lakes, Inc. The seed was moldy, and as a result caused health problems in the Carpenters' cows. Among other claims against Land 0' Lakes Inc., plaintiffs sought damages for emotional distress. After a bench trial, the District Court awarded plaintiffs damages for the emotional distress they suffered when the sick cows fell against them, but stated that plaintiffs were not entitled to noneconomic damages for the emotional distress suffered by seeing their cows eat the moldy seed.

Plaintiffs made a motion for reconsideration to recover damages for all emotional distress suffered as a result of the defective seed. The United States District Court of Oregon reconsidered plaintiffs' motion and found that the majority of plaintiffs' emotional distress was caused by the economic loss they had suffered or the economic loss they feared would continue. The Court stated that Oregon law does not allow recovery for emotional distress generally caused by economic loss and declined to alter the District Court's ruling.