This section contains the nature of the case and procedural background.

Bouillon (P), a married woman, was sick in bed, pregnant, and threatened with miscarriage. Laclede Gaslight Co. (D) came to the door, demanding to read a gas meter. D put his hand in the door. P refused him entrance and demanded he remove his hand. D refused and argued loudly that he should be allowed in. The argument lasted about five minutes. Finally, D left and entered the building by the side or back door, like he should have in the first place. The incident affected P greatly. She was very scared and shocked, and as a result, suffered a miscarriage. P sued D for the injuries suffered. The court found for D. P appealed. D claimed that there was no action stated by P, that the only possible action, in this case, was assault, and P did not prove an assault.

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