In Elden v. Sheldon, (1988) 46 Cal.3d 267, the court rejected an attempt to recover for emotional distress resulting from witnessing an automobile accident that caused the death of a cohabitant partner. The plaintiff alleged that his relationship with the decedent was stable and significant, and paralleled a marital relationship. The court rejected the plaintiff's claims, supporting its decision with three public policy considerations. The first was the state's interest in the marriage relationship, and in particular the "necessity of providing an institutional basis for defining the fundamental relational rights and responsibilities of persons in organized society." (Elden v. Sheldon, supra, 46 Cal.3d at p. 275.) The second was the difficult burden of determining "whether the 'emotional attachments of the family relationship' existed between the parties and whether the relationship was 'stable.' " (Id. at pp. 275-276.) The third was the "need to limit the number of persons to whom a negligent defendant owes a duty of care." (Id. at p. 276.) In sustaining the trial court's demurrer to the complaint, the court emphasized the necessity of drawing a "bright line" in the area, and ruled that the plaintiff could not recover as a matter of law. It specifically declined to follow the rationale of cases allowing recovery by a "bystander who had the 'functional and emotional equivalent' of a nuclear family relationship with the injured person." (Id. at p. 277.)