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

Summary

The Texas Supreme Court affirmed the Court of Appeals, holding that John Freeman, a stepparent who did not contemporaneously perceive the accident, has no cause of action for emotional distress as a bystander. The Court also affirmed the appellate finding that the city's erection of barricades falls within its proprietary functions, leaving the judgment unchanged. Justice Ray, in a concurring opinion, argued that the majority improperly linked the denial of recovery to Freeman's step‑parent status and urged that close familial relationships, not biological ties, should permit recovery.