Brenazia Holt sought emotional-distress damages after waking up to find an apartment-complex maintenance worker in her bed, but she suffered no physical injury and sought no medical treatment after the incident. She sued the apartment owners and manager for premises liability and negligent hiring, retention, and supervision. The Court of Appeals of Georgia affirmed summary judgment for the defendants. It held that Georgia's impact rule barred Holt's negligence-based emotional-distress claims because she could not show a qualifying physical impact that caused a physical injury and then mental suffering. Without that required physical-injury component, the negligence claims could not proceed even though the alleged conduct was deeply disturbing.