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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