California, United States of America
The following excerpt is from Root v. State, E072316 (Cal. App. 2021):
The court, however, had already held that that this was also an actionable invasion of the relatives' right to privacy. (Catsouras v. Department of California Highway Patrol, supra, 181 Cal.App.4th at pp. 868-874.) Given the availability of this well-established cause of action, which would support an award of emotional distress damages, we question the need to recognize a separate cause of action for negligent
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