Garden variety definition
Garden variety means ordinary or commonplace. Garden-variety emotional distress, therefore, is ordinary or commonplace emotional distress. Garden-variety emotional distress is that which simple or usual. In contrast, emotional distress that is not garden-variety may be complex, such as that resulting in a specific psychiatric disorder, or may be unusual, such as to disable one from working.
Garden variety means ordinary or commonplace. Garden-variety
Garden variety means ordinary or commonplace.43 “Garden[-]variety claims refer to claims for compensation for nothing more than the distress that any healthy, well-adjusted person would likely feel as a result of being so victimized.”44 They are restricted to “the negative emotions that [a plaintiff] experience[s] essentially as the intrinsic result of the defendant’s alleged conduct.”45 Claims fall within the ambit of garden-variety anguish where they “do[] not exceed the suffering and loss an ordinary person would likely experience in similar circumstances, and constitute[] matters that are