In Johnson v State of New York (37 N.Y.2d 378 [1975]), the issue was whether the daughter of a hospital patient could recover for emotional harm sustained as a result of negligent misinformation given by the hos-pital that her mother had died. The plaintiff was falsely advised by a state hospital that her mother had died. After plaintiff and her aunt saw the corpse at the funeral, they determined it was not plaintiff's mother. Plaintiff subsequently brought suit seeking, inter alia, to recover for emotional distress. The Court found that liability hinged on the hospital's duty to properly advise the next of kin when a patient dies. "In the light of the Battalla v State of New York and Ferrara v Galluchi cases . . . and the reasoning up-on which they were based," the Court wrote, "recovery for emotional harm to one subjected directly to the tortious act may not be disallowed so long as the evidence is sufficient to show causation and substantiality of the harm suffered, together with a 'guarantee of genuineness' to which the court referred in the Ferrara case." (37 NY2d at 383-384.) The Johnson court observed that historically there had evolved two exceptions to the general rule that re-covery could not be had for negligent infliction of emotional distress (id. at 381-382): "The first is the minority rule permitting recovery for emotional harm resulting from negligent transmission by a telegraph company of a message announcing death. "The second exception permits recovery for emotional harm to a close relative resulting from negligent mishandling of a corpse. Recovery in these cases has ostensibly been grounded on a violation of the relative's quasi-property right in the body. It has been noted, however, that in this context such a 'property right' is little more than a fiction; in reality the personal feelings of the survivors are being protected." The Court in Johnson concluded that the hospital was negligent in failing to ascertain the proper next of kin when it mistakenly transmitted the death notice. The Court of Appeals noted exceptions to the aforesaid general rule in cases of negligent false transmission of notice of the death of a family member and for the negligent mishandling of a corpse, stating that in such cases "there exists an especial likelihood of genuine mental distress, arising from the special circumstances which serves as a guarantee that the claim is not spurious" (p.382). The court, citing Ferrara v. Galluchio, 5 N.Y.2d 16, 176 N.Y.S.2d 996, 152 N.E.2d 249(1958) where the plaintiff suffered mental anguish from a fear of cancer emanating from advice she received regarding her condition two years after the alleged malpractice, and Battalla v. State of New York, 10 N.Y.2d 237 (1961) where the infant plaintiff suffered "severe emotional and neurological disturbances with residual physical manifestations" as a result of being placed on a ski chair lift by defendant's employee who failed to properly lock the belt intended to protect the occupant, concluded (pp. 383-384); "recovery for emotional harm to one subjected directly to the tortious act may not be disallowed so long as the evidence is sufficient to show causation and substantiality of the harm suffered, together with a guarantee of genuineness".