• U.S. District Court
  • 3:12cv537
  • Dec 19 2013 (Date Decided)
  • Shea, J.
Absent facts that would lead to a reasonable conclusion that a plaintiff's emotional distress was severe, a plaintiff's allegation that he suffered emotional distress may be insufficient to allege a claim for intentional infliction of emotional distress, which requires proof of severe emotional distress.