Grotts v. Zahner

989 P.2d 415 · Nevada Supreme Court · 1999

Facts

Kellie Grotts and her fiancé were involved in an accident where her fiancé sustained fatal injuries. Grotts sued Gertrude Zahner for bystander emotional distress. The district court dismissed Grotts's claim, ruling she was not 'closely related' to her fiancé for these purposes.

Issue

Can a plaintiff recover for bystander emotional distress if their relationship to the victim was that of a fiancé, rather than by blood or marriage, satisfying the 'closely related' requirement?

Holding

The court affirmed the district court's dismissal, holding that a non-family relationship, such as an engagement, does not qualify for bystander negligent infliction of emotional distress (NIED) standing as a matter of law.

Rule

For bystander emotional distress claims, the 'closeness of relationship' requirement is generally determined by family membership, either by blood or marriage. Immediate family members qualify as a matter of law, while non-family relationships do not.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.