In such claims, plaintiffs allege that an officer's actions resulted in emotional distress for which compensation should be awarded. Courts recognize emotional distress as the basis for a lawsuit, but are more willing to recognize claims when they are based on flagrant and intentional acts. The leading case for the development of this cause of action was in Dillon v. Legg in which the California Supreme Court developed a negligence theory of liability. A more recent theory of recovery now used by most courts is that of a zone of danger, which limits recovery to plaintiffs who have been placed in fear of bodily harm by some act of the defendant's. A classic example of this is in claims of emotional distress resulting when a defendant shoots at a plaintiff, but hits a person next to the plaintiff. Some courts have required that emotional distress be brought about by witnessing harm to a family member. A majority of courts also require that the emotional trauma be severe and verifiable. Most States also provide some form of official immunity to protect officers from liability for legitimate police functions. The availability of attorney's fees in Federal actions has resulted in most such cases being filed as constitutional violations (usually search and seizure or due process). Such cases have involved plaintiffs' charges based on abandonment of children by police, police harassment, and use of excessive force by police. 20 footnotes.