On November 14, 2014, the Indiana Court of Appeals released its opinion in Clifton v. McCammack, No. 49A02-1404-CT-276. In doing so, it interpreted existing Indiana precedent to allow emotional distress damages to a broader class of persons. In this case, Ray Clifton had been living with his 51-year-old son, Darryl Clifton, who had been caring for his father following Ray’s back surgery six months prior. At 11:15 one morning, Darryl left home on his moped to head to town. Unbeknownst to his father Ray, he was involved in a tragic accident with a negligent driver, Ruby McCammack, who pulled out in front of him.