The Supreme Judicial Court of Maine has held that a mother who became emotionally distressed as a result of seeing her infant son gag and choke on foreign material contained in baby food asserted a valid cause of action for negligent infliction of emotional distress.
Culbert v. Sampson's Supermarkets, Inc., 444 A.2d 433 (Me. 1982).
Samuel F. Reynolds Jr.,
Tort Law - Negligence - Negligent Infliction of Emotional Distress - Bystander Recovery,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol21/iss3/11