Page "Negligent infliction of emotional distress" Paragraph 2

The next step after Dillon was to make optional the element of another person ( so that the injury could be to anything where it would be reasonably foreseeable that such injury would cause some person emotional distress ).

The first such case was Rodrigues v. State, in which the Supreme Court of Hawaii held that plaintiffs could recover for negligent infliction of emotional distress as a result of negligently caused flood damage to their home.

This is generally considered to be the true birth of NIED as a separate tort.