OPINION
KALITOWSKI, JudgeRespondent Geralyn S. Engler brought an action against appellant Beverly J. Wehmas based on an accident that resulted in severe injuries to respondent’s son. Respondent claimed negligent infliction of emotional distress based on her fear for her own safety, the fear she felt for her son’s safety, and the distress she suffered as a result of witnessing injuries to her son. Appellant moved for partial summary judgment, arguing that Minnesota caselaw does not allow for damages for negligent infliction of emotional distress based on either fear for the safety of a third person or witnessing injuries to a third person. The district court denied the motion and certified the question to this court.
FACTS
On April 17, 1997, respondent Geralyn Engler, Brent Renner, and respondent’s two sons, Jacob and Jeffrey, were driving eastbound on 221st Avenue in Oak Grove, Minnesota. When four-and-a-half-year-old Jeffrey stated that he needed to go to the bathroom, Renner pulled to the side of the rural gravel road. Jeffrey walked about 25 feet to the tree line along the ditch so that he was not visible from the road. Respondent stayed alongside the ditch side of the rear passenger door.
Subsequently, appellant Beverly Weh-mas approached westbound on 221st Avenue. Appellant lost control of her car and it veered towards the ditch where Jeffrey was emerging from the wooded area. Respondent thought appellant’s car was going to hit her and run into Renner’s car. Instead, the car missed respondent and struck Jeffrey, throwing him ten feet in the air. Jeffrey sustained severe injuries, including permanent scarring and disfigurement. Since the accident, respondent claims to suffer from depression, posttrau-matic stress disorder, and other mental and physical ailments.
In July 1999, respondent commenced a lawsuit against appellant claiming negligent infliction of emotional distress arising from her fear for her own safety, her fear for her son’s safety, and the distress caused by witnessing her son’s serious injuries. On December 5, 2000, appellant renewed an earlier motion for summary judgment, asking the district court to dismiss respondent’s claims for emotional distress based on fear for or injuries to her son. In the alternative, appellant asked the district court to certify the question of whether respondent may recover for emotional distress based on that claim. The district court denied appellant’s motion for summary judgment and certified, pursuant to Minn. R. Civ.App. 103.03(h), the following question:
Where the plaintiff has asserted a claim for negligent infliction of emotional distress and is found to have:
1. been in the “zone of danger” of physical impact;
2. experienced a reasonable fear for her own safety; and
3. demonstrated physical manifestations of emotional distress,
*871may the plaintiff also recover damages for emotional distress caused by her fear for the safety of her son and from witnessing her son’s injuries.
ISSUES
1. Is the certified question important and doubtful?
2. May respondent recover damages for emotional distress arising from witnessing an accident from within the zone of danger, caused by appellant’s negligence, which caused her fear for her son’s safety and resulted in severe injuries to her son?
ANALYSIS
I.
Both parties assert that the district court’s certified question is “important and doubtful.” We agree. This court may hear an appeal from a denial of a motion for summary judgment “if the trial court certifies that the question presented is important and doubtful.” Minn. R. Civ. App. P. 108.03(h) (2000); Jostens, Inc. v. Federated Mut. Ins. Co., 612 N.W.2d 878, 883 (Minn.2000). Whether a question is important and doubtful raises a legal question and is subject to de novo review by this court. Jostens, 612 N.W.2d at 883.
In determining if a question is important, we balance a number of factors. Id. at 884. A question is increasingly important if it has statewide impact, reversal is likely, lengthy proceedings will be terminated, and a district court’s incorrect ruling will inflict substantial harm on the parties. Id. A question is decreasingly important if it will be affirmed, a trial will moot the issue, reversal will not terminate the action, and reversal would not relieve the parties of a significant burden. Id. But each factor does not warrant equal consideration. Id. “[A] great deal of importance should be placed on whether reversal of the question will terminate the proceedings.” Id.
Here, while our decision on the certified question presented does not terminate the proceedings, it substantially reduces appellant’s responsibility for damages. By answering the certified question in the negative respondent may not present evidence relating to her son’s injuries. This will greatly reduce the scope of the proceedings and affect the amount and type of damages respondent may claim. We thus conclude the issue presented here is important.
“A question is properly certified as doubtful if there is no controlling precedent.” Id. (citation omitted).
That the question is one of first impression is not, however, of itself sufficient to justify certification as doubtful; the question should be one on which there is substantial ground for a difference of opinion.
Id. at 886 (quotation omitted). Because there is no direct controlling caselaw on this issue and other jurisdictions are split on whether to allow recovery for negligent infliction of emotional distress based on the injury to a family member, we conclude that the question presented is doubtful.
Because the certified question presented is both important and doubtful, we grant review.
II.
Appellant contends that the district court erred in denying her motion for summary judgment and in concluding that respondent can recover for her emotional distress arising from appellant’s negligent conduct against respondent’s son.
*872On an appeal from summary judgment, we ask two questions: (1) whether there are any genuine issues of material fact and (2) whether the lower courts erred in their application of the law.
State by Cooper v. French, 460 N.W.2d 2, 4 (Minn.1990) (citation omitted). A reviewing court need not defer to the district court’s application of the law when the material facts are not in dispute. Hubred v. Control Data Corp., 442 N.W.2d 308, 310 (Minn.1989). Here, there are no material facts in dispute, thus our review is de novo.
The elements necessary to maintain a claim for negligence are (1) duty; (2) breach of that duty; (3) that the breach of duty be the proximate cause of plaintiffs injury; and (4) that [the] plaintiff did in fact suffer injury.
Johnson v. State, 553 N.W.2d 40, 49 (Minn. 1996) (citation omitted). Courts have added three additional requirements for the tort of negligent infliction of emotional distress: a plaintiff must show she
(1) was within a zone of danger of physical impact; (2) reasonably feared for her own safety; and (3) suffered severe emotional distress with attendant physical manifestations.
K.A.C. v. Benson, 527 N.W.2d 553, 557 (Minn.1995). Moreover, “[c]ourts historically have been concerned about the reliability of emotional distress claims and have limited liability for those claims.” Carlson v. Illinois Farmers Ins. Co., 520 N.W.2d 534, 535 (Minn.App.1994) (citing Restatement (Second) of Torts § 436A cmt. b (1965)) (other citation omitted).
Both parties agree that all the required elements of a claim for negligent infliction of emotional distress are present here, and it is not disputed that respondent can go forward with her claim for the damages she suffered based on her fear for her own safety.
But no Minnesota case has addressed whether a plaintiff within the zone of danger can recover for emotional distress arising from witnessing an injury to a plaintiffs child. Although not controlling, the discussion of negligent infliction of emotional distress claims in Stadler v. Cross, 295 N.W.2d 552 (Minn.1980), is instructive. In Stadler, the Minnesota Supreme Court held that a plaintiff could not bring an action for intentional infliction of emotional distress for damages based on the injuries to the plaintiffs child because the plaintiff was not in the zone of danger. Id. at 553. In discussing why Minnesota applies the zone-of-danger test, the court mentioned problems with limitless liability to tortfeasors.
A person’s liability for the consequences of her or his actions cannot be unlimited. The limits imposed must be as workable, reasonable, logical, and just as possible. If the limits cannot be consistently and meaningfully applied by courts and juries, then the imposition of liability would become arbitrary and capricious.
Id. at 554. Moreover, the court raised policy concerns about a rule that would allow recovery of damages for negligent infliction of emotional distress for a plaintiff who witnesses injuries to an immediate family member:
what if the third person was the plaintiffs beloved niece or nephew, grandparent, flaneé, or lifelong friend, as dear to the plaintiff as her more immediate family?
Id. at 555.
In addition to Stadler, we are also mindful of a recent decision of this court that held that a “plaintiff cannot recover for negligent infliction of emotional distress arising from witnessing the death of a friend” even when the plaintiff is inside the zone of danger. Carlson, 520 N.W.2d at 535. In discussing where to draw a line *873for liability, the Carlson court suggested that:
[w]hile the tortfeasor had a duty to protect both Carlson and her Mend from physical harm because they were passengers in his car, he had no duty to protect Carlson from distress arising from the fate of her Mend.
Id. at 537. The court further concluded that if it were to find otherwise, the tort-feasor’s liability would be out of proportion to the tortfeasor’s culpability. Id.
Applying the holdings of Sta-dler and Carlson, we conclude that Minnesota appellate courts have been reluctant to extend liability to third persons in negligent infliction of emotional distress cases. In addition, Minnesota has never held that a tortfeasor has a duty to protect a person within the zone of danger from witnessing harm to a family member. Thus, this court would be creating new law in Minnesota if we were to hold that respondent could recover damages for the emotional distress she suffered as a result of witnessing her son’s injuries. See Tobin v. Grossman, 24 N.Y.2d 609, 301 N.Y.S.2d 554, 249 N.E.2d 419, 421 (1969) (stating that allowing the recovery of damages for emotional distress based on an injury to a third party is the creation of new law). Because it is not the function of this court to create new law, we answer the certified question in the negative. See Stubbs v. N. Mem’l Med. Ctr., 448 N.W.2d 78, 80-83 (Minn. App.1989) (refusing to create a cause of action that had not been recognized by the courts or established by the legislature because “[t]he function of this court is primarily decisional and error correcting, rather than legislative or doctrinal”).
DECISION
Notwithstanding the fact that she was within the zone of danger, respondent is not entitled to damages for the emotional distress she suffered as a result of either fearing for her son’s safety or witnessing her son’s injury.
Certified question answered in the negative.