California, United States of America
The following excerpt is from Lubner v. City of Los Angeles, 45 Cal.App.4th 525, 53 Cal.Rptr.2d 24 (Cal. App. 1996):
4 The bystander theory extends the right to recover for negligent infliction of emotional distress suffered as a result of observing the pain and suffering accompanying an injury to another. (See Thing v. La Chusa (1989) 48 Cal.3d 644, 647, fn. 1, 257 Cal.Rptr. 865, 771 P.2d 814.)
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