CALIFORNIA FAMILY LAW
...Unmarried Cohabitors
......Tort Actions
.........Infliction of Emotional Distress
3 Cards On This Topic:

Unmarried cohabitant with stable, significant relationship with cohabitant may not recover for negligent infliction of emotional distress after observation of cohabitant's fatal injury.

Message D left re giving girlfriend's daughter Value Jet ticket [following crash] was "steam" of an irascible temper, not smoke from the fire of death threat actionable in tort.

Homosexual relationship is not significant relationship as matter of law for purposes of recovery for negligent infliction of emotional distress.