146
Opinion of the Court
Rail Corporation v. Gottshall, 512 U. S. 532 (1994), and Metro-North Commuter R. Co. v. Buckley, 521 U. S. 424 (1997).
The FELA plaintiff in Gottshall alleged that he witnessed the death of a co-worker while on the job, and that the episode caused him severe emotional distress. 512 U. S., at 536-537. He sought to recover damages from his employer, Conrail, for "mental or emotional harm . . . not directly brought about by a physical injury." Id., at 544.
Reversing the Court of Appeals' judgment in favor of the plaintiff, this Court stated that uncabined recognition of claims for negligently inflicted emotional distress would "hol[d] out the very real possibility of nearly infinite and unpredictable liability for defendants." Id., at 546. Of the "limiting tests . . . developed in the common law," ibid., the Court selected the zone-of-danger test to delineate "the proper scope of an employer's duty under [the] FELA to avoid subjecting its employees to negligently inflicted emotional injury," id., at 554. That test confines recovery for stand-alone emotional distress claims to plaintiffs who: (1) "sustain a physical impact as a result of a defendant's negligent conduct"; or (2) "are placed in immediate risk of physical harm by that conduct"—that is, those who escaped instant physical harm, but were "within the zone of danger of physical impact." Id., at 547-548 (internal quotation marks omitted). The Court remanded Gottshall for reconsideration under the zone-of-danger test. Id., at 558.
In Metro-North, the Court applied the zone-of-danger test to a claim for damages under the FELA, one element of which was fear of cancer stemming from exposure to asbestos. The plaintiff in Metro-North had been intensively exposed to asbestos while working as a pipefitter for Metro-North in New York City's Grand Central Terminal. At the time of his lawsuit, however, he had a clean bill of health. The Court rejected his entire claim for relief. Exposure alone, the Court held, is insufficient to show "physical im-
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