In Thing v. La Chusa (1989) 48 Cal.3d 644, the Supreme Court held that to state a claim as a bystander for negligent infliction of emotional distress suffered as a result of seeing injury to another person, the bystander plaintiff had, among other things, to be present at the scene of the accident when it occurs and be aware at that time of the injury caused to the victim. This decision holds that virtual presence–by watching the streaming video and audio of the “accident” (or in this case abuse by a health care worker of the plaintiff’s disabled son) from a “nanny cam” to the mother’s cellphone–suffices to meet the presence at the scene element of the Thing v. La Chusa test.