Brief Fact Summary.
A supervisor, Defendant, demeaned and insulted employee, Plaintiff, and told employee that he would be fired. Plaintiff told management about supervisor’s conduct, and he was further insulted and threatened to be fired. Plaintiff sued Defendant to recover damages for an intentional infliction of emotional distress claim. Plaintiff’s claim was dismissed after the trial court granted Defendant’s demurrer to Plaintiff’s complaint. Plaintiff appealed.
Synopsis of Rule of Law.
A Plaintiff who suffered from emotional distress may recover damages from the intentional infliction of emotional distress if Defendant’s conduct was extreme and outrageous.
Manuel Alcorn (Plaintiff), a black man, was employed as a truck driver by employer Anbro Engineering, Inc. (Defendant). Plaintiff’s Caucasian supervisor shouted at and made demeaning remarks about Plaintiff’s race after Plaintiff told another employee not to drive a company truck to a certain area of the work site. Defendant told Plaintiff that he would be fired after completing his work assignment. Upon completion of his work assignment, Plaintiff told Thomas Anderson Sr., an owner of Anbro Engineering Inc., who further demeaned Plaintiff. After those events, Plaintiff was severely humiliated and suffered from mental and physical distress, physical illness, and could not work for several weeks. Plaintiff brought an intentional infliction of emotional distress suit against Defendant and its employees to recover damages.
Whether a plaintiff who has suffered only from emotional distress can recover damages for intentional infliction of emotional distress if the defendant’s conduct was extreme and outrageous.
Yes. A plaintiff who suffered only from emotional distress may recover damages on an intentional infliction of emotional distress claim if defendant’s conduct was so extreme and outrageous that it resulted in severe and traumatic effects on the plaintiff. The question of whether the degree of defendant’s conduct was sufficiently outrageous and extreme to allow a claim of intentional infliction of emotional distress, without physical injuries, is a question for the jury. Here, Manuel Alcorn claimed that he suffered from shock, physical illness, nausea, and insomnia as a result of the shouting and demeaning language from Anbro Engineering Inc. employees targeting at him while working. The employees’ severe and malicious conduct along with the injuries to Alcorn’s mental and emotional well-being was sufficient to bring a claim for intentional infliction of emotional distress. Therefore, trial court erred in dismissing Alcorn’s claim. The order dismissing the claim was reversed.
A plaintiff need not suffer physical injuries to support a claim for intentional infliction of emotional distress.