In Paugh v. Hanks, (1983), 6 Ohio St.3d 72, 6 Ohio B. 114, 451 N.E.2d 759 the Ohio Supreme Court held that a mother had an actionable claim for negligent infliction of emotional distress where she was subjected to severe psychological harm due to three separate incidents in which a car had crashed into her house or yard, causing her to fear for the lives of her children. The Paugh court stated: "A cause of action for the negligent infliction of serious emotional distress may be stated where the plaintiff-bystander reasonably appreciated the peril which took place, whether or not the victim suffered actual physical harm, and, that as a result of this cognizance or fear of peril, the plaintiff suffered severe emotional distress." See id.