Downey v. City of Riverside

Summary

The court held that a bystander seeking negligent infliction of emotional distress need only contemporaneously perceive an injury-producing event and understand that it is injuring a close relative; the plaintiff need not also know how the defendant contributed to the injury. Because Downey alleged that she heard the crash and immediately understood that her daughter was seriously injured, her pleading satisfied the contemporaneous-awareness requirement. The court reversed the Court of Appeal and remanded for further proceedings.