California, United States of America
The following excerpt is from Garcia v. Superior Court (Ro-Tech Industries, Inc.), 169 Cal.App.3d 397, 215 Cal.Rptr. 189 (Cal. App. 1985):
Having earlier relied upon Justice Poche's reasoning in his dissent in Drew v. Drake, we now take the occasion to endorse his conclusion therein, as well. We hold that unmarried cohabitants can state a cause of action for negligent infliction of emotional distress if the plaintiff can demonstrate that the relationship is both stable and significant.
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