What is the test for foreseeability in an action for emotional distress?

Foreseeability deserves little weight here. "'[I]t is clear that foreseeability of the injury alone is not a useful "guideline" or a meaningful restriction on the scope of [an action for damages for negligently inflicted emotional distress.]' [Citation.]" (Burgess v. Superior Court, supra, 2 Cal.4th at p. 1074, brackets in original.) In any event, when a policeman calls a citizen a "fucking retard," some emotional distress is foreseeable, but serious emotional distress is not.