What is the test for damages for emotional distress arising solely from negligent injury to property?

The case of Cooper v. Superior Court (1984) 153 Cal.App.3d 1008, 200 Cal.Rptr. 746 states the law in California. In that case defendant's tractor ran amuck and rolled into plaintiff's house, causing serious damage to a part of the house where the children's playroom was located. Although neither plaintiff nor her children were at home at the time of the accident, [181 Cal.App.3d 884] she claimed emotional distress resulting from the discovery of the damage and the necessary relocation of her family to a hotel until repairs were accomplished. The court specifically addressed the prospect of extending present law to allow for damages for emotional distress resulting solely from negligent injury to property. It concluded: "No California case has allowed recovery for emotional distress arising solely out of property damage, absent a threshold showing of some preexisting relationship or intentional tort. This case involves no preexisting relationship between the parties. Thus, we do not feel it appropriate to extend recovery for emotional distress here." (Id. at p. 1012, 200 Cal.Rptr. 746.)