law-infliction-of-emotional-pain suffering distress | intentional infliction of emotional distress (IIED) |
bystander claims | wrongful death survival statute


Godfrey v. BP Products North America  (Tex.App.- Houston [14th Dist.] Aug. 25, 2009)
(refinery explosion siblings cannot recover under
wrongful death act, no recovery as bystanders
either as they did not witness the calamity, negligent infliction of emotional distress generally not
actionable,
IIED cause of action)
AFFIRMED: Opinion by
Justice Anderson    
Before Justices Anderson, Frost and Guzman  
14-08-00857-CV  Leah Godfrey and Cheri Merritt v. BP Products North America   
Appeal from 212th District Court of Galveston County
Trial Court Judge:
SUSAN ELIZABETH CRISS