The United States Supreme Court held that negligent infliction of emotional distress is a cognizable injury under the Federal Employers' Liability Act provided that the employee satisfies the elements of the common law zone-of-danger test.
Consolidated Rail Corp. v. Gottshall, 114 S. Ct. 2396 (1994).
Terrence M. Lewis,
Employment Law - Federal Employers' Liability Act - Negligent Infliction of Emotional Distress,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol33/iss4/14