In what circumstances will the Court of Appeal overturn a finding that emotional distress can be a cause of action for emotional distress?

In the later case, Drew v. Drake (1980) 110 Cal.App.3d 555, 168 Cal.Rptr. 65, the appeal was also from a judgment entered on a demurrer [148 Cal.App.3d 584] sustained without leave to amend based upon the plaintiff's failure to state a cause of action for emotional distress although she witnessed the killing in an auto accident of the man with whom she had lived for three years as a de facto spouse. The appellate court affirmed and stated: