NY: Grandparents in the "Zone of Danger" Can Recover Emotional Distress Damages

Last week, the New York Court of Appeals ruled that a grandparent in the zone of danger can recover emotional distress damages for the death of their grandchild.  Unlike many jurisdictions, New York does not recognize negligent infliction of emotional distress for bystanders.  However, this holding expands recovery within the "zone of danger" by including grandparents as an "immediate family" member.  Debra Cassens Weiss has the story at ABA Journal.