Brown, Judge. Luis Mayorga appeals from the trial court’s order dismissing his complaint for intentional infliction of emotional distress and negligence against Jim Benton d/b/a Vital Record Solutions (“Vital Records”).[1] He contends that the trial court drew impermissible inferences and made erroneous legal conclusions in its ruling on his intentional infliction of emotional distress claim. With regard to his negligence claim, Mayorga asserts that the trial court should have applied the pecuniary loss exception to the impact rule. For the reasons explained below, we reverse the dismissal of his claim for intentional infliction of emotional distress and affirm the trial court’s dismissal of Mayorga’s ordinary negligence claim. On appeal, we review the trial court’s grant of a motion to dismiss de novo. A motion to dismiss for failure to state a claim upon which relief can be granted should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. In deciding a motion to dismiss, all pleadings are to be construed most favorably to the party who filed them, and all doubts regarding such pleadings must be resolved in the filing party’s favor. (Citations and punctuation omitted.) Dennis v. City of Atlanta, 324 Ga. App. 659 (751 SE2d 469) (2013). Additionally, it is well established that a plaintiff is not required to plead in the complaint facts sufficient to set out each element of a cause of action so long as it puts the opposing party on reasonable notice of the issues that must be defended against. And, in light of the minimal requirements of notice pleading, broad and conclusory allegations are not fatal to a plaintiff’s claim at the motiontodismiss stage. (Citation and punctuation omitted.) Hill v. Bd. of Regents of the Univ. System of Ga., 351 Ga. App. 455, 468 (3) (829 SE2d 193) (2019). Allegations in the Complaint Mayorga’s complaint contains the following allegations: Mayorga’s 15-year-old daughter, Kaitlyn, committed suicide on January 6, 2021, and Mayorga found her body; Mayorga hired Southern Cremations, who in turn hired Vital Records to produce Kaitlyn’s death certificate; Mayorga is in a same-sex marriage and his husband shares the same last name; Southern Cremations had actual knowledge of Mayorga’s same-sex marriage and Kaitlyn’s death from suicide; Vital Records had actual or constructive knowledge of the same; Vital Records prepared a death certificate stamped “DRAFT” and “together with” Southern Cremations delivered it to Mayorga and his husband by e-mail on January 21, 2021, after 5:00 p.m.; and the e-mail was sent by a Southern Cremations employee. The body of Mayorga’s complaint includes an image of a portion of the draft certificate which states: “I AM SO CONFUSED LOL – THE STEP DAD AND THE FATHER HAVE THE SAME LAST NAME?” According to Mayorga’s complaint: It was not “confusing” that Plaintiff Mayorga and his husband had the same last name. Indeed, it was plain from the information provided in the death certificate that Mayorga was in a same sex marriage, and that Kaitlyn had two dads. . . . The statement “I AM SO CONFUSED LOL” was intended to, and did, make fun of Plaintiff Mayorga’s sexual orientation and make light of Kaitlyn’s suicide, which also impugned the home environment Mayorga provided to his daughter. It was not a joke — and certainly not funny — to Mayorga to make fun of the circumstances surrounding Kaitlyn’s death or her home life. . . . The statement . . . subjected [Mayorga] to thoughts that his same sex marriage contributed to his daughter’s depression and suicide. The complaint stated that “Mayorga learned of the death certificate and its callous mockery of both his daughter’s suicide and his same-sex marriage on January 23, 2021[,] the same day he went to retrieve Kaitlyn’s ashes from Defendant Southern Cremations.” The complaint asserts that Mayorga’s husband took him to the hospital in fear for his life the day after Mayorga learned about the draft death certificate. It further alleges that a medical provider wrote the following about Mayorga’s admission: The patient reports that he became suicidal shortly after finding his daughter dead. He went to pick up her ashes on Saturday, and reports that the people at the funeral home made a mockery of him being involved in a same sex marriage, instead of having empathy about his daughter’s death. He reports that after that occurred, he had enough, and truly felt like ending his life, so he could be with his daughter. On January 26, 2021, Mayorga was released from the hospital, where he incurred medical expenses totaling $11,194.50. Mayorga’s complaint sought to recover damages from Vital Records and Southern Cremations based upon negligence and intentional infliction of emotional distress. He alleges that the defendants “acted in concert” to cause emotional distress “by making fun of his daughter’s suicide and his sexual orientation and most importantly tying the two issues together because [they were] on Kaitlyn’s death certificate.” (Emphasis in original.) According to Mayorga, the defendants “denigrat[ed] Kaitlyn’s home life and rais[ed] the question in Mayorga’s mind of his own potential culpability in his daughter’s suicide.” His complaint specifically alleges that he “was already suffering from depression and grieving the loss of his daughter — a fact which was known or should have been known to Defendants — and Defendants’ misconduct aggravated [his] existing mental and emotional condition.” Finally, the complaint states that the “Defendants’ actions showed wil[ ]ful misconduct, malice, fraud, wantonness, oppression, and that entire want of care” such that punitive damages are warranted under OCGA § 51-12-5.1. Documents Attached to the Complaint Mayorga attached a copy of the draft death certificate to the complaint. Several information boxes on the death certificate were either incomplete or blank with a capital “X” placed inside the box. These boxes included: mother’s maiden name; informant’s name; father’s full name; decedent’s education; and disposition date. Mayorga was listed as Kaitlyn’s father and his husband, Matthew Rogers Mayorga, was listed as the informant with a relationship to Kaitlyn of stepdad. In a blank space at the bottom of the death certificate, the following words appeared to the right of a capital “X” identical to that placed in several of the information boxes: MOTHER’S MAIDEN NAME EDUCATION – LAST GRADE COMPLETED I AM SO CONFUSED LOL – THE STEP DAD AND THE FATHER HAVE THE SAME LAST NAME? A “true and correct copy” of the e-mail was also attached to the complaint. This e-mail states in its entirety: Here is the attachment to the revised draft with handwritten corrections. Please look over the personal information and if there are any corrections you can e[-]mail them [to e-mail address for Southern Cremations employee]. If everything is correct you can go ahead and print it out, sign it and e[-]mail it back with Approval + Name in the subject line or you can respond to this e[-]mail saying you approve of the draft. Thank you. The e-mail was sent to an address similar to Mayorga’s husband’s name. The remaining attachment to the complaint documents Mayorga’s medical expenses. It shows that he received in-patient treatment from January 24, 2021 to January 27, 2021. Procedural History The defendants subsequently moved to dismiss Mayorga’s complaint pursuant to OCGA § 9-11-12 (b) (6) for failing to state a claim. In a consolidated order, the trial court granted both motions on the pleadings without holding a hearing.[2] It reasoned that Mayorga’s negligence claim failed because there was no impact and “no evidence that Defendants['] conduct was malicious, wil[ ]ful or wanton,” and nothing on the face of the pleadings showed that the conduct was “directed to the Plaintiff.” In its view, “[t]he language of the document appears to be internal and shared amongst themselves and not directed towards [Mayorga].” Finally, it found that Mayorga’s intentional infliction of emotional distress claim should be dismissed because the alleged conduct did not rise to the level of extreme and outrageous as a matter of law and was not directed at Mayorga. 1. Intentional Infliction of Emotional Distress. In related enumerations of error, Mayorga contends that the trial court erred by dismissing his intentional infliction of emotional distress claim on the grounds that the alleged conduct was not sufficiently extreme or outrageous or directed at him.[3] As discussed below, we agree that Mayorga’s intentional infliction of emotional distress claim survives a motion to dismiss. Georgia has long recognized a cause of action for intentional infliction of emotional distress. However, the burden which the plaintiff must meet in order to prevail in this cause of action is a stringent one. To prevail, a plaintiff must demonstrate that: (1) the conduct giving rise to the claim was intentional or reckless; (2) the conduct was extreme and outrageous; (3) the conduct caused emotional distress; and (4) the emotional distress was severe. The defendant’s conduct must be so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community. Whether a claim rises to the requisite level of outrageousness and egregiousness to sustain a claim for intentional infliction of emotional distress is a question of law. (Citations and punctuation omitted.) Racette v. Bank of America, 318 Ga. App. 171, 179 (3) (733 SE2d 457) (2012). Additionally, “it is well settled that the alleged conduct must have been directed at the plaintiff in order to be actionable under a theory of intentional infliction of emotional distress.” (Citations and punctuation omitted.) Doe v. Roe, 362 Ga. App. 23, 29 (3) (d) (864 SE2d 206) (2021). (a) In support of his argument that his complaint alleges conduct that was sufficiently outrageous, Mayorga points to the following authority: Comment f, § 46 (1), of the Restatement (Second) states that the extreme and outrageous character of the conduct “may arise from the actor’s knowledge that the other is peculiarly susceptible to emotional distress by reason of some physical or mental condition or peculiarity. The conduct may become heartless, flagrant, and outrageous when the actor proceeds in the face of such knowledge, where it would not be so if he did not know.” Bridges v. Winn-Dixie, 176 Ga. App. 227, 230 (1) (335 SE2d 445) (1985). See also Williams v. Voljavec, 202 Ga. App. 580, 582 (415 SE2d 31) (1992) (physical precedent only). The majority of cases addressing whether a particular claim rises to the level of extreme or outrageous conduct involve summary judgment and evidence presented outside of the parties’ pleadings, including the cases Vital Records cites in its brief to this Court. See, e.g., Roddy v. Tanner Med. Center, 262 Ga. App. 202, 205-206 (585 SE2d 175) (2003); Northside Hosp. v. Ruotanen, 246 Ga. App. 433, 436 (541 SE2d 66) (2000). There are relatively few reported cases addressing the dismissal of a claim for intentional infliction of emotional distress, particularly with regard to whether the alleged conduct is sufficiently outrageous. In Walker v. Walker, 293 Ga. App. 872 (668 SE2d 330) (2008), we reversed the trial court’s dismissal of a pro se plaintiff’s complaint, finding that his complaint asserted that the defendants’ intentional conduct was extreme and outrageous and that this caused him severe emotional distress. The claim was thus properly pled as to its essential elements. See Love v. Morehouse College, 287 Ga. App. 743, 746 (652 SE2d 624) (2007) (reversing trial court’s grant of motion to dismiss claims including intentional infliction of emotional distress; “measuring the basis of those claims at this early stage of the proceedings is premature”). Id. at 874-875 (2) (b). See also Nicholson v. Windham, 257 Ga. App. 429, 433-434 (3) (571 SE2d 466) (2002) (trial court erred in dismissing intentional infliction of emotional distress claim premised upon employers’ conduct in soliciting plaintiff to participate in illegal real estate scheme and instructing her not to disclose it); Gillis v. American Gen. Life & Acc. Ins. Co., 222 Ga. App. 891, 893 (476 SE2d 648) (1996) (reversing trial court’s dismissal of intentional infliction of emotional distress claim involving disparagement of plaintiff in the business community). Compare Renton v. Watson, 319 Ga. App. 896, 903-904 (3) (739 SE2d 19) (2013) (affirming trial court’s dismissal of intentional infliction of emotional distress claim where defendant withdrew application for arrest warrant containing false allegations before the plaintiff was arrested); Racette, 318 Ga. App. at 173, 179-180 (3) (affirming trial court’s dismissal of intentional infliction of emotional distress claim premised on defendants’ conduct in conducting a foreclosure sale despite alleged knowledge of inaccuracies in published foreclosure advertisement with regard to senior lien status and deed book and page numbers); Scouten v. Amerisave Mtg. Corp., 284 Ga. App. 242, 244 (3) (643 SE2d 759) (2007) (affirming grant of motion to dismiss because “complaint does not allege or show that [any of the defendant's employees'] conduct was ‘extreme’ or ‘outrageous’” in case involving alleged unnecessary dissemination of information to other employees that plaintiff/employee had been discharged for theft), reversed on other grounds, Scouten v. Amerisave Mtg. Corp., 283 Ga. 72 (656 SE2d 820) (2008); Lincoln Nat. Life Ins. Co. v. Davenport, 201 Ga. App. 175, 176 (410 SE2d 370) (1991) (affirming dismissal of intentional infliction of emotional distress claim premised upon the denial of benefits under a disability insurance policy). In this case, Mayorga’s complaint sets forth all of the essential elements of a claim for intentional infliction of emotional distress and alleges that both defendants actually knew that his daughter had committed suicide and that he was in a same-sex marriage and that based on this knowledge, there was no actual confusion about the two last names listed for the father and stepfather. It further alleged that the defendants made the statement “I am so confused LOL” with the intent to “make fun of Mayorga’s sexual orientation” on a death certificate after his child had committed suicide and that they acted in concert to do so. Finally, it asserted that both defendants “were specifically and acutely aware” that he “was grieving” and “especially vulnerable to the infliction of emotional and mental distress.” It is within the understanding of an average member of the community that the parent of a teenager who dies from suicide struggles with the question of why their child would take such a step and what about that child’s life could have motivated them to do so. It is similarly understood that teenagers want to fit in and fear being judged and teased for being different. With these common understandings in mind and construing the complaint in the light most favorable to Mayorga, we cannot say that it is not outrageous, as a matter of law, for a professional working in the field of issuing death certificates to feign confusion and laugh about why a dead teenager’s gay fathers have the same last name, intentionally place these comments on any version of a death certificate, and intentionally share these comments, which could be understood to make fun of the dead teenager’s home life, with her grieving father. Accordingly, we cannot conclude, at this early stage of the proceedings, that Mayorga would not be entitled to relief under any state of provable facts with regard to the outrageous aspect of his claim. Cf. McCoy v. Ga. Baptist Hosp., 167 Ga. App. 495, 498-499 (2) (306 SE2d 746) (1983) (finding genuine issue of material fact precluded summary judgment on mother’s intentional infliction of emotional distress claim where hospital employee telephoned mother, with known emotional problems following stillbirth of baby, to state that infant’s body was in a freezer and the mother should come retrieve it). Presiding Judge Doyle’s dissent relies almost exclusively upon summary judgment and jury verdict cases to conclude that Mayorga’s complaint fails to allege facts sufficiently outrageous to survive a motion to dismiss for failure to state a claim.[4] And she asserts that “the words as written on the death certificate . . . must be viewed in isolation because Mayorga does not complain of a series of acts.”[5] In our view, the analysis in this particular case should not be limited to the universe of facts contained within the exhibits to the complaint as proposed by Presiding Judge Doyle’s dissent. This is not a case addressing a contract or a will. Compare Lord v. Lowe, 318 Ga. App. 222, 223-224 (741 SE2d 155) (2012) (affirming trial court’s grant of motion to dismiss based upon condition of bond agreement attached to plaintiff’s complaint). Moreover, the narrow view of the facts proposed by Presiding Judge Doyle’s dissent[6] ignores the rule “that the extreme and outrageous character of the conduct may arise from the actor’s knowledge that the other is peculiarly susceptible to emotional distress.” Bridges, 176 Ga. App. at 230 (1). This Court should not decide the propriety of this particular motion to dismiss based upon cases in which the parties have had an opportunity to fully develop the facts demonstrating the outrageous nature of the conduct at issue, particularly when the complaint alleges sufficient facts to conclude that Mayorga was especially susceptible to emotional distress following his teenage daughter’s suicide, and that Vital Records had the requisite knowledge. In Presiding Judge Dillard’s dissent, he concludes that “the statement in the draft death certificate permits multiple interpretations by an objective person, and this, in turn, precludes Mayorga’s [ ] claim from going forward.” He cites no Georgia cases supporting this conclusion in the context of a motion to dismiss. Instead, he relies upon non-binding cases from other jurisdictions concluding that the particular vague threat before the court was not sufficient to withstand a motion to dismiss. An examination of the facts before each of those courts shows they are readily distinguishable and that many involved statements made in the context of domestic disputes and divorce proceedings.[7] None of these cases remotely address language — which Presiding Judge Dillard recognizes could be shown to have been intended to mock the sexual orientation of the parents of a teenager who had committed suicide — placed on a death certificate by a professional in that industry. They are therefore unpersuasive. In sum, after comparing the facts alleged in this case to the facts of other Georgia cases in which claims for intentional infliction of emotional distress survived a motion to dismiss, we cannot say that the facts of this case are so qualitatively different that the plaintiff’s complaint should not also survive. See, e.g., Gillis, 222 Ga. App. at 893 (disparagement of plaintiff in business community). While we conclude that Mayorga’s complaint survives this early stage of litigation, we express no opinion as to the merits of this case at the summary judgment or directed verdict stage. (b) With regard to whether a dismissal was warranted based on the trial court’s conclusion that the conduct was not directed towards Mayorga, we agree with Mayorga’s argument that the trial court failed to construe the allegations of the complaint in his favor. The trial court’s order states that “[t]he language of the document appears to be internal and shared amongst themselves and not directed towards [Mayorga].” (Emphasis supplied.) While discovery in this case ultimately may prove the trial court’s assumption correct, Gillis, 222 Ga. App. at 893, such assumptions are improper at the motion to dismiss stage, particularly when Mayorga’s complaint alleges that the defendants acted in concert.[8] Discovery in this case could reveal evidence showing that the defendants had communications outside of the e-mail attached to the complaint that would support the conclusion that the conduct was directed at Mayorga. (c) Vital Records contends that the exhibits attached to the complaint mandate the conclusion that it did not direct its conduct at Mayorga. Assuming, without deciding, that these documents can properly be considered on motion to dismiss without converting the motion to one for summary judgment,[9] they do not change our conclusion that the trial court erred by dismissing the intentional infliction of emotional distress claim.[10] If the defendants acted in concert to intentionally harm Mayorga as alleged in the complaint, the fact that Southern Cremations sent the e-mail rather than Vital Records matters not. And while Vital Records asserts that the e-mail address to which the death certificate was delivered shows that it was actually delivered to Mayorga’s husband, we cannot determine from the e-mail address alone who actually used it, whether it was a shared address, or the defendants’ knowledge of any such use. For the above-stated reasons, the trial court erred by granting Vital Records’ motion to dismiss Mayorga’s intentional infliction of emotional distress claim. 2. Negligence. Mayorga contends the trial court erred by dismissing his negligence claim based upon the impact rule because the pecuniary loss exception applies. In Georgia, a person cannot recover in ordinary negligence for emotional distress damages without satisfying the impact rule, which has three elements: (1) a physical impact to the plaintiff; (2) the physical impact causes physical injury to the plaintiff; and (3) the physical injury to the plaintiff causes the plaintiff’s mental suffering or emotional distress. A failure to meet any one of these requirements is fatal to a recovery [of damages for mental suffering]. (Citation and punctuation omitted.) Eley v. Fedee, 362 Ga. App. 618, 622 (1) (869 SE2d 566) (2022). As the Supreme Court of Georgia has explained: [I]n order to avoid limitless liability out of all proportion to the degree of a defendant’s negligence, and against which it is impossible to insure without imposing unacceptable costs on those among whom the risk is spread, the right to recover for negligently caused emotional distress must be limited. (Citation and punctuation omitted.) Coon v. Med. Center, 300 Ga. 722, 734 (4) (797 SE2d 828) (2017). The impact rule has no application in three circumstances. In cases where mere negligence[[11]] is not relied on, but the conduct complained of is malicious, wilful, or wanton, mental pain and suffering may be recovered without application of the impact rule, provided that it is directed toward the plaintiff. Another carefully circumscribed exception to the physical impact rule authoriz[es] recovery of damages by a parent where the parent and her child both suffered a physical impact that caused them both physical injuries, even if the parent’s emotional distress arose not only from her physical injury but also from watching her child suffer and die. Finally, the pecuniary loss rule . . . provides for a third circumstance in which the impact rule does not apply. (Citations and punctuation omitted.) Eley, 362 Ga. App. at 623 (1). We find no merit in Mayorga’s claim that the pecuniary loss rule saves his ordinary negligence claim. This rule allows for a recovery of damages for mental injury despite the lack of an impact. See Eley, 362 Ga. App. at 623 (1). The genesis of the pecuniary loss rule originates from the following language in an 1892 opinion by the Supreme Court of Georgia: The law protects the person and the purse. The person includes the reputation. The body, reputation and property of the citizen are not to be invaded without responsibility in damages to the sufferer. But outside these protected spheres, the law does not yet attempt to guard the peace of mind, the feelings or the happiness of every one, by giving recovery of damages for mental anguish produced by mere negligence. There is no right, capable of enforcement by process of law, to possess or maintain without disturbance any particular condition of feeling. The law leaves feeling to be helped and vindicated by the tremendous force of sympathy. The temperaments of individuals are various and variable, and the imagination exerts a powerful and incalculable influence in injuries of this kind. There are many moral obligations too delicate and subtle to be enforced in the rude way of giving money compensation for their violation. Perhaps the feelings find as full protection as it is possible to give, in moral law and a responsive public opinion. The civil law is a practical business system, dealing with what is tangible, and does not undertake to redress psychological injuries. Chapman v. Western Union Tel. Co., 88 Ga. 763, 772-773 (15 SE 901) (1892). Following the issuance of “[m]any cases contain[ing] various interpretations and applications of the law as announced in the Chapman case,” this Court summarized our view of the impact rule and “what is meant by an injury to a person’s purse” as follows: In cases where mere negligence is relied on, before damages for mental pain and suffering are allowable, there must also be an actual physical injury to the person, or a pecuniary loss resulting from an injury to the person which is not physical; such an injury to a person’s reputation, or the mental pain and suffering must cause a physical injury to the person. Kuhr Bros. v. Spahos, 89 Ga. App. 885 (81 SE2d 491) (1954), overruled on other grounds, Whiten v. Orr Constr. Co., 109 Ga. App. 267, 270 (136 SE2d 136) (1964). In Westview Cemetery v. Blanchard, 234 Ga. 540, 543 (B) (216 SE2d 776) (1975), the Supreme Court stated the rule more succinctly as follows: “Where there is a physical injury or pecuniary loss, compensatory damages include recovery for accompanying ‘mental pain and suffering’ even though the tortious conduct complained of is merely negligent.” In Ob-Gyn Assocs. of Albany v. Littleton, 259 Ga. 663 (386 SE2d 146) (1989), the Supreme Court discussed the history of the pecuniary loss rule and its application to cases involving injury to property before holding: We reiterate the rule that for a pecuniary loss to support a claim for damages for emotional distress, the pecuniary loss must occur as a result of a tort involving an injury to the person even though this injury may not be physical. An injury to the reputation would be such an injury. Id. at 667 (2) (B). The above-quoted language from Littleton is now used to determine the application of the pecuniary loss rule, even though it differs from that of Kuhr Bros. and Westview Cemetery by requiring that the pecuniary loss occur as a result of a tort. See White v. State, 305 Ga. 111, 122, n.10 (823 SE2d 794) (2019) (“When a high court finds discordant opinions among its own . . . precedents the court generally follows its decision in the most recent case, which must have tacitly overruled any truly inconsistent holding.”) (citation and punctuation omitted; emphasis in original); Oliver v. McDade, 297 Ga. 66, n.1 (772 SE2d 701) (2015) (“Oliver II“) (citing Littleton definition of pecuniary loss rule); Lee v. State Farm Mut. Ins. Co., 272 Ga. 583, 585 (1), n.3 (533 SE2d 82) (2000) (same). In Owens v. Gateway Mgmt. Co., 227 Ga. App. 815 (490 SE2d 501) (1997), we addressed whether “medical bills and lost time from work” resulting from the emotional distress suffered during a home invasion qualified as a pecuniary loss under the Littleton test. Id. at 816. We concluded that the plaintiff’s negligence claim against the apartment management company failed because the only pecuniary loss plaintiff complains of on appeal is that incurred due to medical bills and lost time from work she allegedly incurred because of emotional distress following the incident in question. As such, we conclude that that pecuniary loss is not of the same type as that referred to in [Littleton] because it is itself a form of emotional distress damage as opposed to pecuniary loss occurring as the result of a tort involving an injury to the person even though this injury may not be physical such as an injury to reputation. To hold otherwise would be to allow bootstrapping of an extreme nature. (Citation and punctuation omitted.) Id. Consistent with the reasoning of Owens, this Court has held that medical expenses, psychological treatment fees, and lost income incurred as a result of emotional distress do not qualify as a pecuniary loss. Eley, 262 Ga. App. at 627 (3); Grizzle v. Norsworthy, 292 Ga. App. 303, 306 (2) (664 SE2d 296) (2008). Based on this line of cases, it appears that Mayorga’s medical bills do not qualify as a pecuniary loss that will allow him to recover in ordinary negligence for his emotional distress. Mayorga points to a different line of cases, Oliver v. McDade, 328 Ga. App. 368 (762 SE2d 96) (2014) (“Oliver I“) and Nationwide Mut. Fire Ins. Co. v. Lam, 248 Ga. App. 134 (546 SE2d 283) (2001),[12] to assert that his medical expenses are a pecuniary loss. We disagree. First, the portion of the majority opinion in Oliver I that addressed the pecuniary loss rule was vacated by the Supreme Court in Oliver II. See 297 Ga. at 68 (vacating Division 2 of Oliver I ). Second, our decision in Lam was wrongly decided. In Lam, a husband and wife were involved in an automobile accident in which their vehicle was damaged. 248 Ga. App. at 135. Although the wife suffered no physical injury, she alleged that the accident aggravated a preexisting mental illness, the treatment of which resulted in medical expenses. Id. We concluded that the wife suffered a pecuniary loss based upon her medical bills and the damage to personal property in the accident. Id. at 138 (2). We then found that she had suffered “an injury to her person, consisting of aggravation of her preexisting mental illness, which before the collision had been stable for years.” Id. In his dissent to Oliver I, Presiding Judge Andrews advocated that this Court overrule Lam, explaining: In permitting a plaintiff to seek damages for negligently caused emotional distress in the absence of physical injury, Lam failed to address the prior holding of Owens. . . . Lam wrongly applied the pecuniary loss rule by finding that the medical bills and lost wages incurred by [the plaintiff] supplied the pecuniary loss for her claim. Just as in Owens, the only pecuniary loss in Lam is that incurred due to medical bills and lost time from work [the plaintif
