The California Court of Appeals has held that a cause of action may be maintained in strict liability for physical injuries resulting from emotional shock suffered in witnessing injuries or death inflicted upon a close family member as the result of a defectively designed or manufactured product.
Shepard v. Superior Court, 76 Cal. App. 3d 16, 142 Cal. Rptr. 612 (1977).
Torts - Strict Product Liability - Recovery for Emotional Distress,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol17/iss2/13