(2005) (confirming that physical harm requirement persists). The plaintiffs have failed to plead any resulting physical harm manifested by objective symptomatology. In any event, Matthew’s parents would not be able to recover for negligent infliction of emotional distress because they fail the proximity requirement. Massachusetts law does. not require that a relative claiming negligent infliction of emotional distress was at the scene of the harm to a family member, but it does require that “the shock follow[ ] closely on the heels of the accident.” Stockdale v. Bird & Son, Inc., 399 Mass. 249, 503 N.E.2d 951, 953 (1987) (quoting Ferriter v. Daniel O’Connell’s Sons, 381 Mass. 507, 413 N.E.2d 690, 697 (1980)). That requirement has been strictly applied. See Stockdale, 503 N.E.2d at 953 (<HOLDING>); Cohen v. McDonnell Douglas Corp., 389 Mass.
holding that the defendants mother validly consented to a search of a motor home parked in the driveway of her house when the motor home was connected by an electrical cord to her house the mother was observed entering the motor home repeatedly and the mother apparently had supervisory authority over two teenage girls who were inside the motor home because it was reasonable to conclude that the mother had common authority over the motor home sufficient to give valid consent holding that a mother who did not see sons injured body until twentyfour hours after an accident at funeral home was not entitled to recover holding that although son was eighteen years old and paid rent mother could consent to search of sons bedroom where nothing suggested mother lacked access to room holding that mother who did not learn of her sons death in airplane crash until seven hours after the crash could not recover holding that claim for sons suicide was not actionable