What is the test for emotional distress in a motor vehicle accident?

12 Even then, as one case has recently stated in describing the proof burdens of an emotional distress claim in those cases involving only a financial injury, "... before recovery for emotional distress may be allowed in a case in which the only other damage is financial, there must be a showing of 'substantial' injury other than the emotional distress, or the emotional distress damage itself must be 'severe, substantial or enduring.' " (Torres v. The Automobile Club of Southern California (1995) 36 Cal.App.4th 972, 984-985, 43 Cal.Rptr.2d 147, review granted on specific issues Sept. 28, 1995 (SO48329).)