Alabama law does not allow a cause of action for negligent infliction of emotional distress. See, e.g. AALAR, Ltd., Inc. v. Francis, 716 So.2d 1141, 1144 (Ala.1998) (“negligently causing emotional distress is not an independent tort in Alabama, but, rather, that it is part and parcel of the traditional tort of negligence”). Neither does it permit every plaintiff to maintain a suit for negligence or wantonness when the only damages are mental or emotional harm. Id. at 1146 (“Courts therefore have placed substantial limitations on the class of plaintiffs that may recover for emotional injuries.... ”). Instead, “[i]n negligence actions, Alabama follows the ‘zone-of-danger’ test, which limits recovery of mental anguish damages to those plaintiffs who sustain 7 So.2d 447, 449 (Ala.1999) (<HOLDING>); Wal-Mart Stores, Inc. v. Bowers, 752 So.2d
holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any holding that plaintiffs who were in the car during car accident could recover for emotional damages because they were within zone of danger holding that plaintiffs were not in the zone of danger and could not recover for emotional distress because they were at not home when their house caught on fire holding person is at grave risk of death when directly in the line of fire or when in a zone of danger holding that the trial court erred in allowing the jury to award mentalanguish damages to the plaintiff homeowners based on their negligence claim where fire destroyed the house but they suffered no physical injury and were not in the zone of danger