What are the causes of action for negligent infliction of emotional distress?

California, United States of America


The following excerpt is from City of Murrietta v. Superior Court of Riverside Cnty., E051221, Super.Ct.No. RIC495559 (Cal. App. 2011):

4. As to Hooks's fifth cause of action for negligent infliction of emotional distress, the motion for summary adjudication should have been granted. Hooks is a "direct victim" of the City's alleged wrongful conduct, not a "bystander." As such, she may not assert a cause of action for negligent infliction of emotional distress. (Burgess v. Superior Court (1992) 2 Cal.4th 1064, 1072.)

5. All further statutory references are to the Government Code unless otherwise indicated.

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