Jun Chi Guan v. Tuscan Dairy Farms
This dissenting opinion concerns a case where plaintiff Shao Zhen Kwan, a grandmother, sought damages for emotional injuries after witnessing her grandson's fatal accident. The defendants moved for summary judgment, asserting that a grandparent does not qualify as "immediate family" for emotional distress claims under New York law and that the grandmother did not sufficiently witness the event. The Supreme Court denied this motion. The dissenting judge argues that established precedent does not preclude grandparents from "immediate family" status, citing their special legal recognition and caregiving roles. Furthermore, the judge contends that contemporaneous awareness, rather than literal witnessing, is sufficient for such claims. Therefore, the dissent concludes that the Supreme Court correctly denied the defendants' motion to dismiss.