This document provides an IRAC analysis of the case Christensen v. Superior Court. The issue is whether persons other than those who contracted for funeral/cremation services or have a statutory right to dispose of remains can recover damages for emotional distress from negligent or intentional mishandling of remains. The rule discusses rights to control remains disposition under section 7100. The analysis discusses the plaintiffs, defendants, allegations, and courts' rulings. The court of appeals broadened who could recover for emotional distress, but the Supreme Court modified this, finding not all plaintiffs were entitled to recover for intentional infliction due to lack of intention to cause them distress specifically.