Eckenrode v. Life of America Insurance

Brief Fact Summary.

Eckentode (plaintiff) sued Life of America Insurance (defendant) for intentional infliction of emotional distress.

Synopsis of Rule of Law.

For purposes of claims of intentional infliction of emotional distress, economic coercion may be sufficient to qualify as outrageous conduct.

Facts.

Plaintiff’s husband obtained life insurance from the defendant in the event of the husbands accidental death. If the husband died accidentally, the plaintiff was to receive $5000 immediately. After the plaintiff’s husband was murdered, the defendant refused to pay the $5000, despite the fact the plaintiff was left with no assets. The defendant had no reason for denying liability and informed the plaintiff there were still unresolved details about the murder and urged her to settle for less than the $5000. Plaintiff brought suit for intentional infliction of emotional distress.

Issue.

Whether for purposes of claims of intentional infliction of emotional distress, economic coercion may be sufficient to qualify as outrageous conduct.

Held.

Yes. For purposes of claims of intentional infliction of emotional distress, economic coercion may be sufficient to qualify as outrageous conduct.

Concurrence.

None

Discussion.

Generally, intentional infliction of emotional distress requires: (1) the defendant’s conduct must be extreme and outrageous, (2) the defendant’s intention must be to cause mental distress, (3) the plaintiff must suffer from severe emotional distress, (4) The defendant’s conduct must be the causation of the distress. When a plaintiff is especially vulnerable to mental harm and the defendant know this, their conduct may rise to the level of outrageous. Here, because the defendant knew of the unstable emotional state the plaintiff was in due to knowledge of her husband’s death and the fact they attempted to force her to settle during this period, their conduct qualifies as outrageous.