Can a bystander who witnessed a motor vehicle accident recover damages for emotional distress?

The limits on recovery by a bystander "reflect a public policy exception which limits the right of a bystander who did not suffer physical injury and was not threatened with such injury to recover damages for the emotional distress the bystander suffered as a result of witnessing negligent conduct which caused physical injury to a third person. If any and all bystanders who witnessed the injury-causing event were permitted to recover for ensuing emotional distress, the defendant's liability could be out of all proportion to the degree of fault. [Citations.]" (Christensen v. Superior Court, supra, 54 Cal.3d at p. 885, 2 Cal.Rptr.2d 79, 820 P.2d 181.) ⁵