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Medlin v. Allied Inv. Co. - 217 Tenn. 469, 398 S.W.2d 270 (1966)

Rule:

Two factors must concur in order to outweigh the policy against allowing an action for the infliction of mental disturbance: a) the conduct complained of must have been outrageous, which means that it is not tolerated in civilized society, and b) as a result of the outrageous conduct, there must be serious mental injury. There are two valid policies fighting for recognition. One is the interest in a judicial climate that does not become burdened with trivial lawsuits. The second is the interest that a person has in being free from unreasonable emotional disturbance. The law has developed to the extent that the personal interest in peace of mind is protected from "outrageous" interference that results in substantial emotional damage, and at the same time the policy of protecting the judicial process from trivial claims has been protected by disallowing claims which are not founded on conduct which can be characterized as "outrageous."

Facts:

Defendant, Allied Investment Company, was in the business of lending money, with the loans secured by a mortgage or deed of trust. Plaintiffs, Mr. and Mrs. Roy Medlin were defendant’s clients who rendered payments through checks starting September 1962. Due to defendant’s negligence in keeping its records regarding plaintiffs’ payments, it caused two notices of default to be sent to the plaintiff. When plaintiffs called to clarify the payment issue, defendant’s agent was abusive on the telephone. Thereafter, plaintiff filed a tort action against defendant for intentional interference with plaintiffs’ peace of mind. The trial court sustained defendant’s demurrer to the action on the ground that plaintiffs had failed to state a claim on which relief could be granted. Plaintiffs appealed.

Issue:

Was the conduct complained of sufficient to grant relief to the plaintiff?

Answer:

No.

Conclusion:

The Supreme Court of Tennessee reviewed the trial court's ruling to determine whether the law recognized and protected a right to emotional tranquility where recovery was sought to mental or emotional disturbance alone, unconnected with any independently actionable or objectively ascertainable injury. The court held that a person's peace of mind was protected from outrageous interference that caused emotional damage but that the conduct alleged in the mortgagee's declaration was not sufficiently outrageous to allow recovery. The court noted that liability was found only where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all bounds of decency. According to the court, liability would not extend to mere insults, indignities, threats, annoyances, petty oppression, or other trivialities.

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