Harris v. Jones

281 Md. 560, 380 A.2d 611 (1977)



Four elements must coalesce to impose liability for intentional infliction of emotional distress: (1) The conduct must be intentional or reckless; (2) The conduct must be extreme and outrageous; (3) There must be a causal connection between the wrongful conduct and the emotional distress; and (4) The emotional distress must be severe. 


Plaintiff sued defendant company and defendant supervisor for intentional infliction of emotional distress because defendant supervisor ridiculed plaintiff's speech impediment.  The plaintiff had been under treatment for a nervous condition for 6 years prior to the commencement of defendant’s harassment. A verdict was entered in favor of plaintiff, but this was reversed on initial appeal. On further review, the court determined that plaintiff was required to prove that defendant supervisor's conduct was intentional or reckless, that his conduct was extreme and outrageous, that it caused plaintiff's emotional distress, and that the distress was severe.


Is humiliation enough to constitute “severe emotional distress” as an intentional infliction of emotional distress?




The reversal was affirmed by the court because, although defendant's conduct was intentional, plaintiff failed to prove that the emotional distress he suffered was severe. The evidence shown for plaintiff's distress was vague and did not indicate the intensity nor the length of the distress. The court did not consider any of the other elements of the tort as plaintiff's failure to prove the necessary element of severe distress prevented recovery.

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