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On Aug.17, 2018, the court upheld a Portee (bystander) claim for the negligent infliction of emotional distress (NIED) even though the bystander was not related to the deceased infant or the infant’s biological parent. Moreland v. Parks, ____ N.J. Super. ____ ( App. Div. 2018).
On Jan. 30, 2009, two-year old I’Maya Moreland, while holding the hand of Valerie Benning waiting to cross the street, was killed when struck by a vehicle and thrown 65 feet. I’Maya was not Benning’s biological daughter; she was the daughter of I’Asia Moreland, Benning’s same-sex partner.
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