Lois M. Freeman, Petitioners v. City of Pasadena, Respondent

Summary

The Texas Supreme Court affirmed the Court of Appeals, holding that John Freeman could not recover for emotional distress as a bystander because he did not contemporaneously perceive the accident that injured his stepsons. The Court applied the Dillon v. Legg foreseeability factors and declined to extend a duty of care to a step‑parent who was not present at the scene.