Wilks v. Hom

In Wilks v. Hom (1992) 2 Cal.App.4th 1264, a mother and two minor daughters were injured, and a third minor daughter was killed, in an explosion. (Id. at p. 1267.) The survivors sued for their injuries and for the wrongful death of the decedent. Their damages totaled almost $3 million; the decision did not state how much was allocated to the wrongful death cause of action. (Id. at pp. 1267-1268.) The issue in the case was whether the mother could recover damages for negligent infliction of emotional distress as a result of witnessing the injuries to her daughters. There was no question of excessive damages.