Rachel E. Schack and Dylan E. Schack, Appellants v. Steven M. Schack, Personal Representative of the Estate Of…

Summary

The Alaska Supreme Court affirmed the superior court’s summary‑judgment grant, holding that Alaska’s bystander exception does not permit a negligent infliction of emotional distress claim when the tortfeasor and the injured relative are the same person, and that the D.S.W. factors do not support creating a new duty of care to expand NIED liability. The decision rests on Alaska precedent, California authority, and policy considerations against opening the floodgates to new liability.