State Rubbish Collectors Ass’n v. Siliznoff

Brief Fact Summary. Defendant, a non-member of Plaintiff association, collected garbage from a company Plaintiff claimed was within its domain. Plaintiff’s agent allegedly demanded that Defendant surrender the money derived from the collection or suffer physical consequences, in response to which Defendant attended Plaintiff’s meeting and signed notes promising to pay. Plaintiff sued Defendant to force payment of the notes, and Defendant argued they were unenforceable and counter-sued for intentional infliction of mental distress.

Synopsis of Rule of Law. There exists a cause of action for intentional infliction of emotional distress for serious threats of physical violence whether or not such threats technically rise to the level of assault. When one acts outrageously, intends to cause such distress and does so, he is liable for the emotional distress and the bodily harm resulting therefore.

Facts. Defendant collected garbage from a company Plaintiff claimed was properly subject to collection by one of its members. Defendant alleged that agents of Plaintiff threatened him with physical violence if he did not make an arrangement to pay Plaintiff’s member the money derived from the collection, and demanded that he attend a meeting of the association. Defendant also alleged that he was only allowed to leave that meeting after he signed notes promising to pay the money demanded. When Plaintiff sued to collect on the notes, Defendant claimed they were invalid and counter-sued for intentional infliction of mental distress. The jury returned a verdict in favor of Defendant for both the notes and the intentional infliction of mental distress.

Issue. Was the jury correct to find Plaintiff liable for the damages resulting from Defendant’s mental suffering, even though Plaintiff caused no actual physical damage?

Held. Yes. The verdict was sustained. One who behaves outrageously in causing severe emotional distress to another is liable for the damages stemming from that emotional distress, including physical injury. It is a question for the jury whether outrageous conduct has caused emotional distress and physical injury.

Discussion. The Court focuses upon the role of a jury and its likely capabilities in reaching this decision. Recognizing that a jury may not be equipped to accurately track the cause of a physical injury, the Court makes paramount the question of whether one has engaged in outrageous conduct such as would warrant imposition of liability for resulting emotional and physical damages. The Court is clearly concerned about unleashing a whole new range of causes of action, and attempts to use the outrageousness standard to limit that possibility.