In State v. Eaton 101 Nev. 705, 710 P.2d 1370 (1985), the Court first recognized a cause of action for negligent infliction of emotional distress where a bystander suffers "serious emotional distress which results in physical symptoms caused by apprehending the death or serious injury of a loved one due to the negligence of the defendant." The "physical impact" requirement has also been applied where the negligent act is alleged to have been committed directly against the plaintiff.