Cote v. Litawa

The question to be decided is whether a mother whose child is negligently struck and injured by the automobile of another, may recover for physical injuries caused by the fright or shock of learning of such injury to her child immediately after its occurrence, the mother not having witnessed the accident, nor been aware of any danger to her child before its happening, nor being in any position to be struck herself or to fear for her own safety.

The case being before us on motions of the defendant to dismiss the mother’s action therefor and a count in her husband’s action to recover for loss of…