Keck v. Jackson
In Keck v. Jackson, 122 Ariz. 114, 593 P.2d 668 (1979), the court enumerated three factors that must be established to recover for emotional distress from witnessing harm to another:
(1) "the shock or mental anguish of the plaintiff must be manifested as a physical injury";
(2) "the emotional distress must result from witnessing an injury to a person with whom the plaintiff has a close personal relationship, either by consanguinity or otherwise";
(3) "the plaintiff/bystander must himself have been in the zone of danger so that the negligent defendant created an unreasonable risk of bodily harm to him." Id. at 115-16, 593 P.2d at 669-70.