What is the test for a cause of action for negligent infliction of emotional distress?
California, United States of America
The following excerpt is from Carrera v. Alefosio, G053270 (Cal. App. 2017):
Plaintiffs' cause of action for negligent infliction of emotional distress fares no better because it is not an independent tort. (Catsouras v. Department of California Highway Patrol (2010) 181 Cal.App.4th 856, 875-876.)
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