Heiner v. Moretuzzo

In Heiner v. Moretuzzo (1995), 73 Ohio St.3d 80, 1995 Ohio 65, 652 N.E.2d 664, the Ohio Supreme Court re-emphasized that recovery for the negligent infliction of emotional distress is allowed only in those instances where a person is a bystander to the accident or experiences fear associated with physical consequences to him or herself. Id. at 85, citing High v. Howard, 64 Ohio St.3d at 85, reversed on other grounds, Gallimore v. Children's Hosp. Med. Ctr. (1993), 67 Ohio St. 3d 244, 1993 Ohio 205, 617 N.E.2d 1052.