Debra Godelia died after suffering cardiac arrest while wearing a LifeVest external defibrillator manufactured by ZOLL Services. Her husband and son sued under Florida law, alleging strict products liability, negligence, fraud, warranty violations, and negligent infliction of emotional distress. The district court dismissed all claims. The Eleventh Circuit held that the complaint stated cognizable common-law claims relating to the device and that federal law did not preempt those claims, so it reversed dismissal of the products, negligence, fraud, warranty, and related claims. The court reached a different result on negligent infliction of emotional distress. Although the plaintiffs alleged severe emotional symptoms after witnessing the death, their generalized allegations of muscle and stomach pain did not amount to the physical injury required under Florida law. The court affirmed dismissal of that claim, while allowing the plaintiffs to seek amendment if they could allege more concrete physical injuries. The judgment was affirmed in part, reversed in part, and remanded.