In what circumstances can a plaintiff recover for emotional distress?

unless the distress suffered has been severe." Hailey v. Cal. Physicians' Serv., 158 Cal. App. 4th 452, 476 (2007). However, a plaintiff may recover for emotional distress alone without any resulting physical disability. Id. Severe emotional distress means emotional distress of such substantial quantity or enduring quality that no reasonable man in a civilized society should be expected to endure it. Id. "It 'may consist of any highly unpleasant mental reaction such as fright, grief, shame, humiliation, embarrassment, anger, chagrin, disappointment or worry.'" Id.