Court of Appeals Extends ‘Immediate Family Member’ in Bystander Recovery Cases to Include Grandparents and Grandchildren

In a matter of first impression, the Court of Appeals in Tenhoppen v Glemboski held that grandchildren and grandparents alike fall within the scope of “immediate family members” who may pursue bystander recovery under negligent infliction of emotional distress claims. The panel’s unanimous decision, which is slated for publication, looked at jurisprudence from within Michigan, as well as sister states, finding support from other statutory schemes that are limited to a class of “immediate family members,” that include both grandparents and grandchildren within their scope. Accordingly, grandparents and grandchildren may now pursue bystander recovery on NIED claims in Michigan.

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