The Supreme Court held that an employee who suffered prolonged asbestos exposure could not recover under FELA for negligently inflicted emotional distress unless, and until, the employee had manifested physical symptoms of disease.
Metro-North Commuter R.R. Co. v. Buckley, 117 S. Ct. 2113 (1997,).
Employment Law - Federal Employers' Liability Act,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol36/iss4/12