KIE: In Tebbutt v. Virostek (1985), the New York Court of Appeals dismissed a suit for emotional distress caused by the stillbirth of an infant allegedly resulting from medical malpractice. Steinbock argues that parents should be able to recover for emotional anguish in cases like Tebbutt. Some states currently allow them to do so by recognizing prenatal wrongful death suits, which focus on the unborn. Steinbock maintains that a better legal approach would be to allow recovery for the negligent infliction of emotional distress upon the parent(s). She presents a six-part argument that discusses: (1) the facts of Tebbutt; (2) wrongful death actions and their extension to the unborn; (3) prenatal torts and prenatal wrongful death; (4) the recognition of harms or wrongs to nonviable fetuses; (5) the legal implications of recognizing fetal personhood; and (6) recognizing parental rights in cases like Tebbutt without recognizing the fetus as a person.