What is the test for a cause of action for severe emotional distress?

An absence of duty notwithstanding, the allegations were insufficient as a matter of law to support a cause of action for severe or serious emotional distress. "'[S]evere' means substantial or enduring as distinguished from trivial or transitory. Severe emotional distress means, then, emotional distress of such substantial quantity or enduring quality that no reasonable man in a civilized society should be expected to endure it. [] 'It is for the court to determine whether on the evidence severe emotional distress can be found.'" (Fletcher v. Western National Life Ins. Co. (1970) 10 Cal.App.3d 376, 397.)