Can a plaintiff recover for nervous shock from what they heard about the accident scene?

In both these cases the plaintiff was not physically present at the accident site, but observed the condition of the victim in the hospital. Until these cases were decided, the courts had drawn an arbitrary line beyond which recovery was not possible. In order for a plaintiff to recover for nervous shock, he or she was required to have a sensory perception of the actual events, which shock brought on a mental injury or illness. In Jaensch v. Coffey the court held that it was the combination of what the plaintiff saw in the hospital and what she heard regarding her husband's condition, which brought on her nervous shock. I have found no cases where a court has awarded damages on the basis of what a plaintiff heard in the absence of having firsthand perception of the precipitating event, or its aftermath.