Samms v. Eccles case brief

Samms v. Eccles case brief summary
358 P.2d 344 (1961)

CASE SYNOPSIS

In her tort action for intentional infliction of severe emotional distress, plaintiff appealed from a judgment of the trial court (Utah), which dismissed her complaint against defendant on the ground that it failed to state a cause of action.

CASE FACTS
Defendant engaged in a pattern of sexual harassment against plaintiff, calling her repeatedly and urging her to have sexual relations with him. Charging that his proposals were insulting, indecent, and obscene, she filed an action for intentional infliction of severe emotional distress.

PROCEDURAL HISTORY
The trial court dismissed her complaint for failure to state a claim on which relief was granted.

DISCUSSION

• The court reversed the judgment, 
• The actions also were required to be outrageous, intolerable, and an offense against generally accepted standards of decency and morality. 
• The court found that plaintiff's complaint met the test. 
• The circumstances described in her complaint were aggravated and were beyond the usual circumstances of sexual solicitation, which were not actionable even if offensive.
• Accordingly, the court ruled that the trial court erred in dismissing the complaint.

RULES

• An action existed for severe emotional distress, although not accompanied by bodily impact or physical injury, where the defendant intentionally engaged in some conduct 
• (a) with the purpose of inflicting emotional distress, or 
• (b) where any reasonable person knew that distress resulted from his conduct. 

CONCLUSION
The court reversed the judgment of the trial court, which had dismissed plaintiff's tort action for intentional infliction of severe emotional distress for failure to state a claim on which relief was granted.

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