iied claim (Minnesota) · Go Syfert
← Minnesota issues

iied claim in Minnesota

5 Minnesota opinions name it 1 courts 1996–2024 2 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Langeslag v. KYMN Inc.green
minn · 2003 · cited in 4 Minnesota opinions naming this issue, 2015–2024
2 sentences

2024The elements of an IIED claim are as follows: “(1) the conduct must be extreme and outrageous; (2) the conduct must be intentional or reckless; (3) it must cause emotional distress; and (4) the distress must be severe.” Langeslag v. KYMN Inc., 664 N.W.2d 860, 864 (Minn. 2003) (quotation omitted).

2024The elements of an IIED claim are as follows: “(1) the conduct must be extreme and outrageous; (2) the conduct must be intentional or reckless; (3) it must cause emotional distress; and (4) the distress must be severe.” Langeslag v. KYMN Inc., 664 N.W.2d 860, 864 (Minn. 2003) (quotation omitted).

34
Hubbard v. United Press International, Inc.green
minn · 1983 · cited in 2 Minnesota opinions naming this issue, 2015–2024
2 sentences

2024Plaintiffs face a heavy burden to establish mental distress severe enough to prevail on an IIED claim: “[t]he law intervenes only [when] the distress inflicted is so severe that no reasonable [person] could be expected to endure it.” Hubbard, 330 N.W.2d at 439 (quoting Restatement (Second) of Torts § 46 comment j (1965)).

2024Plaintiffs face a heavy burden to establish mental distress severe enough to prevail on an IIED claim: “[t]he law intervenes only [when] the distress inflicted is so severe that no reasonable [person] could be expected to endure it.” Hubbard, 330 N.W.2d at 439 (quoting Restatement (Second) of Torts § 46 comment j (1965)).

22
Dowell v. Contra Costa Countygreen
cand · 2013 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015See Dowell v. Contra Costa Cnty., 928 F. Supp. 2d 1137 , 1156- 57 (N.D.

2015See Dowell v. Contra Costa Cnty., 928 F. Supp. 2d 1137 , 1156- 57 (N.D.

11
Singleton v. Christ the Servant Evangelical Lutheran Churchgreen
minnctapp · 1996 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015IIED claims are “‘sharply limited to cases involving particularly 10 egregious facts.’” Singleton v. Christ the Servant Evangelical Lutheran Church, 541 N.W.2d 606, 614 (Minn. App. 1996) (quoting Hubbard, 330 N.W.2d at 439 ), review denied (Minn. Mar. 19, 1996).

2015IIED claims are “‘sharply limited to cases involving particularly 10 egregious facts.’” Singleton v. Christ the Servant Evangelical Lutheran Church, 541 N.W.2d 606, 614 (Minn. App. 1996) (quoting Hubbard, 330 N.W.2d at 439 ), review denied (Minn. Mar. 19, 1996).

11
Darrow v. Dillingham & Murphy, LLPgreen
dc · 2006 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Cal. 2013) (holding that employer did not engage in “outrageous” conduct by allegedly asking employee to use unlawful timekeeping practices); Darrow v. Dillingham & Murphy, LLP, 902 A.2d 135, 139 (D.C. 2006) (holding that employer did not engage in “extreme and outrageous” conduct by allegedly retaliating against employee for refusing to participate in unlawful billing). 11 Thus, the state district court correctly concluded that Peterson did not create a genuine issue of material fact with respect to the first element of her IIED claim.

11
Odegard v. Finnegreen
minnctapp · 1993 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015Hubbard, 330 N.W.2d at 438-39 ; Odegard v. Finne, 500 N.W.2d 140, 144 (Minn. App. 1993) (affirming grant of summary judgment to defendant on IIED claim because plaintiff “failed to present any evidence linking her alleged damages to any actions” of defendant).

2015Hubbard, 330 N.W.2d at 438-39 ; Odegard v. Finne, 500 N.W.2d 140, 144 (Minn. App. 1993) (affirming grant of summary judgment to defendant on IIED claim because plaintiff “failed to present any evidence linking her alleged damages to any actions” of defendant).

11
Pikop v. Burlington Northern Railroadgreen
minn · 1986 · cited in 1 Minnesota opinions naming this issue, 1996–1996
1 sentence

1996See Pikop v. Burlington N.R.R., 390 N.W.2d 743, 752-53 (Minn.1986) (holding that employee’s state law IIED claim was not preempted by RLA because IIED does not stem from differing interpretations of CBA, but from tort law), cert. denied, 480 U.S. 951 , 107 S.Ct. 1616 , 94 L.Ed.2d 800 (1987).

11
Adkins v. United Statesgreen
scotus · 1987 · cited in 1 Minnesota opinions naming this issue, 1996–1996
1 sentence

1996See Pikop v. Burlington N.R.R., 390 N.W.2d 743, 752-53 (Minn.1986) (holding that employee’s state law IIED claim was not preempted by RLA because IIED does not stem from differing interpretations of CBA, but from tort law), cert. denied, 480 U.S. 951 , 107 S.Ct. 1616 , 94 L.Ed.2d 800 (1987).

11
Burlington Northern Railroad v. Gulatigreen
scotus · 1987 · cited in 1 Minnesota opinions naming this issue, 1996–1996
2 sentences

1996See Pikop v. Burlington N.R.R., 390 N.W.2d 743, 752-53 (Minn.1986) (holding that employee’s state law IIED claim was not preempted by RLA because IIED does not stem from differing interpretations of CBA, but from tort law), cert. denied, 480 U.S. 951 , 107 S.Ct. 1616 , 94 L.Ed.2d 800 (1987).

1996See Pikop v. Burlington N.R.R., 390 N.W.2d 743, 752-53 (Minn.1986) (holding that employee’s state law IIED claim was not preempted by RLA because IIED does not stem from differing interpretations of CBA, but from tort law), cert. denied, 480 U.S. 951 , 107 S.Ct. 1616 , 94 L.Ed.2d 800 (1987).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Statutes the citing opinions construe

MN § Minn. Stat. § 181.932 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 39 (2002–2026) CA 39 (2015–2026) VT 38 (2002–2026) OR 27 (1995–2025) AK 20 (1990–2025) ME 18 (1998–2026) OH 18 (2001–2026) HI 18 (1994–2026) MI 17 (2014–2026) NC 15 (2001–2026) PA 13 (2004–2025) NY 13 (2022–2026) KY 12 (2001–2025) IL 11 (2020–2026) NM 8 (2004–2025) UT 8 (2011–2026) IN 8 (2007–2018) NJ 7 (2020–2026) NV 7 (1998–2020) AZ 6 (2014–2024) FL 6 (2006–2025) MA 5 (2013–2026) ID 5 (2007–2026) TN 5 (2016–2024) DC 5 (2014–2026) MN 5 (1996–2024) LA 4 (2000–2024) DE 4 (2020–2026) MS 3 (2012–2023) WA 3 (2025–2026) CO 3 (2024–2026) OK 3 (2016–2025) WV 2 (2025–2026) SD 2 (2017–2017) ND 2 (2025–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check