Is there a cause of action for negligent infliction of emotional distress?

A cause of action for negligent infliction of emotional distress is limited to very specific factual circumstances under either a so-called "bystander" theory, or when a plaintiff is deemed a "direct victim" of conduct presumed to cause severe emotional distress. Burgess v. Superior Court, 2 Cal. 4th 1064 (1992). Plaintiff concedes that he does not seek to state a claim under the "bystander" variant, which is triggered when a plaintiff suffers severe emotional distress as a result of witnessing a close family

Page 8