Campanano

Plaintiffs and appellants Naomi and Jeolfa Campanano appeal from a summary judgment entered against them and in favor of defendant and respondent California Medical Center (Hospital). We are asked to determine the accrual date of a cause of action for “bystander” negligent infliction of emotional distress. We conclude, as a general rule, that the cause of action accrues at the time of the injury-producing event and, in this case, no facts justifying delayed accrual have been presented. Accordingly, the statute of limitations ran in this case prior to the filing of the complaint. We affirm the summary judgment.

Facts and Procedural Background

Plaintiffs are the mother and sister of Raquel Directo. On December 28, 1992, Directo was admitted into Hospital in a coma. On January 9, 1993, plaintiffs witnessed an intravenous line (I.V.) improperly placed in Directo’s arm. Another relative of Directo, who was a registered nurse, recognized that the I.V. was infusing fluid directly into Directo’s arm rather than into her vein. Plaintiffs observed discoloring, blistering and swelling of Directo’s arm, as a result of the infusion. Plaintiffs informed Hospital personnel of their…