In Dillon v. Legg (1968) 68 Cal.2d 728, the California Supreme Court permitted a mother to recover damages from a negligent motorist for the emotional distress she suffered as a consequence of witnessing the accident that caused the death of her child. Equating the duty to avoid causing emotional harm to bystanders with the foreseeability they might suffer such harm, the court articulated a set of guidelines to aid in the resolution of the issue of duty in bystander recovery cases. Duty would be owed if, in light of the expressed guidelines, the accident and harm were reasonably foreseeable. (Dillon, supra, 68 Cal.2d at p. 741.) The Dillon court stated that in determining whether a defendant should reasonably foresee the injury to the plaintiff, or owe the plaintiff a duty of due care, "the courts will take into account such factors as ... (1) Whether plaintiff was located near the scene of the accident as contrasted with one who was a distance away from it. (2) Whether the shock resulted from a direct emotional impact upon plaintiff from the sensory and contemporaneous observance of the accident, as contrasted with learning of the accident from others after its occurrence. (3) Whether plaintiff and the victim were closely related, as contrasted with an absence of any relationship or the presence of only a distant relationship." (Dillon, supra, 68 Cal.2d at pp. 740-741.) The Supreme Court first announced the right of a parent, who is not personally injured by an accident, to recover damages for the shock of witnessing injury to another. To more accurately define the foreseeability element of duty (id. at p. 740), the Dillon Court set forth guidelines: The plaintiff must be located near the scene of the accident; the shock must result from a direct emotional impact on plaintiff from the sensory and contemporaneous observance of the accident; the plaintiff and the victim must be closely related. (Id. at pp. 740-741.)