Harris v. Jones

Court of Appeals of Maryland, 1977.

281 Md. 560, 380 A.2d 611

Facts

Harris, the plaintiff, has a speech impediment and has a very nervous temperament. Jones is the Defendant and the foreman at the factory where he works. Jones repeatedly makes fun of Harris and Harris states that his doing so makes his mental disabilities considerably worse.

Procedural History

Trial court ruled in favor of defendant, resulting in $3500 in compensatory damages and $15,000 in punitive damages.

Issue

What does it take for conduct intended to harm individuals emotionally become something that an actor is liable for?

Holding

The court affirms the appellate courts stance of finding the defendant’s actions to be not bad enough to be tortious.

Rule

There are four elements that must be met for the tort of intentional infliction of emotional distress to exist

1. The conduct must be intentional or reckless;
2. The conduct must be extreme and outrageous;
3. There must be a casual connection between the wrongful conduct and the emotional distress;
4. The emotional distress must be severe.

The intermediate appellate court found the first two elements but not the second two.

Policy Arguments

The actions of the foreman, the defendant, though reprehensible, were found to be within the scope of possibility on the manufacturing floor.