Can a mother who witnessed her daughter's injuries at the hospital after the accident sustain a cause of action for emotional distress?

Ten years ago, this court held in Powers v. Sissoev (1974) 39 Cal.App.3d 865, 114 Cal.Rptr. 868, that a mother who witnessed her daughter's injuries at the hospital 30 to 60 minutes after the accident could not sustain a cause of action for her emotional distress. We recognized that "the [Dillon ] rule allowing recovery for emotional shock and its after effect is not necessarily limited to the narrow facts involved in that case." (Id., at p. 873, 114 Cal.Rptr. 868.) Nevertheless, we declined to apply Dillon "where the shock ... resulted from seeing the daughter 30 to 60 minutes after the accident and thereafter under circumstances not materially different from those undergone by every parent whose child has been injured in a nonobserved and antecedent accident." (Id., at p. 874, 114 Cal.Rptr. 868.)