In Balthazor v. Little League Baseball, Inc. (1998) 62 Cal.App.4th 47, the minor filed an action for injuries sustained when he was struck by a wild pitch during a baseball game. His mother asserted a cause of action for emotional distress. The court, in affirming summary judgment, found that the league did not increase the risk of injury to the minor plaintiff and, therefore owed no duty to him. (Id. at pp. 48-53.) In addressing the mother's NIED claim, the court noted: "Because we hold primary assumption of risk bars the minor's negligence action, his mother's claim for negligent infliction of emotional distress is similarly barred. (Dillon v. Legg (1968), 68 Cal.2d at p. 733 ... 'In the absence of the primary liability of the tortfeasor, ... we see no ground for an independent and secondary liability for claims for injuries by third parties.'.)" (Id. at p. 53, fn 1.)