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Eckenrode v. Life of Am. Ins. Co. - 470 F.2d 1 (7th Cir. 1972)

Rule:

The elements of a prima facie case for the tort of intentional infliction of severe emotional distress are: (1) Outrageous conduct by the defendant; (2) The defendant's intention of causing, or reckless disregard of the probability of causing emotional distress; (3) The plaintiff's suffering severe or extreme emotional distress; and (4) Actual and proximate causation of the emotional distress by the defendant's outrageous conduct.

Facts:

Plaintiff beneficiary, who was a resident of Pennsylvania, filed this three-count diversity complaint to recover damages for severe emotional injury suffered as a result of the deliberate refusal of defendant Life of America Insurance Company to pay her the proceeds of the insurer's policy covering the life of her husband. Plaintiff sought recovery of the face value amount and compensatory and punitive damages for intentional infliction of emotional distress. The district court dismissed the suit after holding that the plaintiff failed to state a claim on which relief could be granted. The plaintiff appealed.

Issue:

Did the trial court err, citing failure to state a claim on which relief could be granted, err in dismissing plaintiff beneficiary's suit to recover damages for intentional infliction of emotional distress as a result of the alleged deliberate refusal of defendant insurer to pay her the proceeds from her husband's life insurance policy?

Answer:

Yes

Conclusion:

The United States Court of Appeals for the Seventh Circuit reversed the decision of the district court and held that the insurer's bad-faith refusal to pay on the insurance policy of beneficiary's late husband, coupled with economic coercion tactics to get beneficiary to settle, rose to the level of "outrageous conduct" necessary to sustain a claim for intentional infliction of emotional distress. The Court stated the elements of a prima facie case for the tort of intentional infliction of severe emotional distress were: (1) outrageous conduct by the defendant; (2) defendant's intention of causing, or reckless disregard of the probability of causing, emotional distress; (3) plaintiff's suffering severe or extreme emotional distress; and (4) actual and proximate causation of the emotional distress by the defendant's outrageous conduct. The Court did not allow punitive damages to be awarded to plaintiff as an additional recovery because the outrageous quality of defendant's conduct formed the basis of the action. The rendition of compensatory damages were sufficiently punitive.

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