Rodriguez v. Motor Exp., Inc.
Justice Dorsey concurs with the analysis of Jerry Rodriguez's bystander claim, specifically addressing his right to recover for emotional distress caused by a near-miss with Guzman's car, even without physical impact. The opinion reviews Texas jurisprudence on emotional distress claims, citing key cases such as Hill v. Kimball, Gulf, C. & S.F. Ry. v. Hayter, and Houston Elec. Co. v. Dorsett, which established that physical impact is not a prerequisite for recovery. It further notes that physical manifestation of emotional injury is also not required, as affirmed in Boyles v. Kerr. Dorsey concludes that Rodriguez should not be barred from recovery for his emotional injuries despite not being physically struck.