In Christensen v. Superior Court (1991) 54 Cal.3d 868, the mortuary defendants contracted with the cemetery defendants to perform cremations. The cemetery defendants mishandled the decedents' remains. The defendant mortuaries knew or should have known of the cemetery's malfeasance. (Christensen, at pp. 878-879.) The Supreme Court held family members could recover emotional distress damages because the mortuaries and crematories owed them an independent tort duty arising from a special relationship. (Id. at p. 891.) The court recognized that "'once a mortuary ... undertakes to accept the care, custody and control of the remains, a duty of care must be found running to the members of decedent's bereaved family.'" (Id. at pp. 887-888.) The Christensen court determined it was foreseeable that mishandling human remains likely would cause serious emotional distress to members of the decedent's immediate family. In reaching this conclusion, the court cited with approval Allen v. Jones (1980) 104 Cal.App.3d 207.