Bowen v. Lumbermens Mut. Cas. Co., 183 Wis. 2d 627, 517 N.W.2d 432 (1994)

A mother who witnessed the aftermath of a bicycle accident that killed her son brought a claim for negligent infliction of emotional distress. At the time, Wisconsin law barred her claim because she was not in the “zone of danger” and her distress had no physical manifestations. Abrahamson’s majority opinion established new rules governing claims of negligent infliction of emotional distress, and they allowed the mother to pursue her claim.