Bass v. Nooney Co. established negligent infliction of emotional distress as an independent tort in Missouri. The Missouri Supreme Court, however, left open the question of if and when a bystander can recover under this cause of action. The question remained unanswered for seven years until the Asaro decision. This Note will first analyze that decision, then focus on the traditional rules and restrictions on bystander recovery, and finally set forth for consideration a proposed rule that is less restrictive than the one adopted by the Missouri Supreme Court.

Included in

Law Commons



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.