What is the tort of negligent infliction of emotional distress?

The courts of Hawaii have taken similar stands. In recognizing the tort of negligent infliction of emotional distress, the court in Rodrigues v. State (1970) 52 Hawaii 156, 472 P.2d 509, held that liability in such cases would be determined "most justly by the application of general tort principles." (Id., at p. 520.) Liability may be found where it was reasonably foreseeable that serious mental distress to the plaintiff could result from the defendant's conduct. (Id., at pp. 520-521.)