The following excerpt is from Air Crash Disaster Near Cerritos, California, On August 31, 1986, In re, 967 F.2d 1421 (9th Cir. 1986):
The Thing court criticized dicta from Krouse v. Graham, 19 Cal.3d 59, 137 Cal.Rptr. 863, 562 P.2d 1022 (1977), that concluded that persons who were not present at the accident scene could recover damages for the emotional distress they suffered when they were told of the injury or when they later arrived at the scene. Thing, 257 Cal.Rptr. at 872, 771 P.2d at 821.
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