Eileen M. Dunphy, Plaintiff-Respondent v. James L. Gregor, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that an unmarried cohabitant who is engaged to be married satisfies the intimate familial relationship requirement for bystander negligent infliction of emotional distress. The Court reasoned that the relationship’s depth, duration, and mutual dependence justify extending the duty of care, and it rejected the dissent’s call for a bright‑line rule limiting recovery to legally married parties. Justice GARIBALDI dissented, arguing the standard is too open‑ended.