In Eskin the Court held that a person who observes an injured family member shortly after an injury producing accident may pursue a claim for NIED. It is worth noting that the Court did not overrule its prior holdings in Camper v. Minor, 915 S.W.2d 437 (Tenn. 1996) or Lourcey v. Estate of Scarlett, 146 S.W.3d 48 (Tenn. 2004). Eskin, No. No. W2006-01336-SC-R11-CV, slip op. at 12.
Here's the link to the opinion: