What is the bystander test for emotional distress caused by witnessing the death of a family member?

3. Bystander Test. The bystander test, a variation on the zone of danger test, is followed in some jurisdictions and permits a plaintiff witnessing the death or severe injury to a family member to recover, even though not in the zone of physical danger. See, e.g., Dillon v. Legg, 68 Cal.2d 728, 69 Cal.Rptr. 72, 441 P.2d 912, 915-16, 920-21 & n. 5 (1968) (mother could recover for emotional distress caused by witnessing death of daughter even though there was no physical impact and she was not in the zone of physical danger).