Langeslag v. KYMN Inc.

664 N.W.2d 860 (Minn. 2003) · Supreme Court of Minnesota · July 17, 2003 · No. C7-02-635

Summary

The Supreme Court of Minnesota held that the evidence was insufficient to submit Wayne Eddy's intentional infliction of emotional distress counterclaim against Sharon Langeslag to the jury. The court concluded that Langeslag's alleged false police reports, threats to bring litigation, and workplace arguments were not extreme and outrageous conduct, and that Eddy lacked sufficient evidence establishing severe emotional distress and causation. The court reversed and remanded for entry of judgment consistent with its opinion.

Court
Supreme Court of Minnesota
Writing for the Court
Gilbert, Justice
Jurisdiction
Minnesota
Decision date
July 17, 2003
Docket number
C7-02-635
Procedural posture
After a jury awarded Wayne Eddy $535,000 on his intentional-infliction-of-emotional-distress counterclaim, the district court denied Langeslag's motion for judgment notwithstanding the verdict, new trial, or remittitur. The Minnesota Court of Appeals affirmed, and the Minnesota Supreme Court granted review solely on whether the counterclaim was properly submitted to the jury.
Standard of review
The denial of judgment notwithstanding the verdict is reviewed de novo. The evidence is viewed in the light most favorable to the prevailing party, and the judgment must be affirmed if any competent evidence reasonably tends to sustain the verdict. The same standard applies to motions for directed verdict and JNOV.
Precedential value
Published, precedential opinion of the Supreme Court of Minnesota
Parties
Sharon Langeslag v. KYMN Inc., a/k/a KYMN Radio, Wayne Eddy, Jeff Johnson, et al.
Disposition
reversed_and_remanded

Topics

intentional infliction of emotional distressappellate procedurestandard of reviewdamagesemployment law

Practice areas

tortsemployment lawappellate procedureremedies

Questions Presented

  1. Whether the district court erred by submitting Eddy's intentional-infliction-of-emotional-distress counterclaim to the jury when the evidence did not establish extreme and outrageous conduct.
  2. Whether the evidence established that Langeslag's conduct caused Eddy severe emotional distress.
  3. Whether, in a case involving complex medical causation and multiple possible sources of distress, the claimant's testimony and inconclusive medical records were sufficient to submit an intentional-infliction-of-emotional-distress claim to the jury.

Holdings

  1. The evidence, even viewed in the light most favorable to Eddy, did not establish conduct so atrocious, intolerable, or beyond the boundaries of decency as to satisfy the extreme-and-outrageous-conduct element of intentional infliction of emotional distress. False police reports, threats to bring a lawsuit, and repeated workplace arguments, considered individually and cumulatively, were legally insufficient under the circumstances.
  2. Eddy did not present sufficient evidence that Langeslag's conduct caused severe emotional distress. In a case involving complex medical issues, multiple possible causes, and claimed physical symptoms, the claimant's testimony and inconclusive medical records were insufficient to establish causation or the severity of the distress.
  3. The district court erred as a matter of law by submitting Eddy's intentional-infliction-of-emotional-distress counterclaim to the jury because the evidence was legally insufficient to establish extreme and outrageous conduct, causation, and severe emotional distress.

Key quotations

“Intentional infliction of emotional distress consists of four distinct elements: (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.” (864)
“Extreme and outrageous conduct is conduct that is "utterly intolerable to the civilized community."” (865)
“Even when considered cumulatively, Langeslag's conduct does not constitute extreme and outrageous conduct "utterly intolerable in a civilized society."” (868)
“The appropriate method of proving the severity and causation of emotional distress is through medical testimony.” (870)

Factual background

Sharon Langeslag and KYMN owner Wayne Eddy had a volatile employment relationship marked by frequent arguments, shouting, threats of litigation, and workplace conflict. Langeslag reported Eddy to police on two occasions, once concerning the sale of Minnesota Vikings tickets and once claiming that Eddy would not allow her to leave his office; police took no further action on either report. Langeslag also frequently argued with Eddy, used vulgar language, and invaded his personal space. Eddy attributed various physical symptoms and medical conditions to the relationship, but the medical records did not establish that Langeslag's conduct caused severe emotional distress.

Procedural history

Langeslag sued KYMN and Eddy asserting employment-related statutory and tort claims. Eddy counterclaimed for intentional infliction of emotional distress, defamation, and intentional interference with a contractual relationship. The jury found for Eddy on all submitted counterclaims and awarded $535,000 for intentional infliction of emotional distress; following a separate bench trial, the district court rejected Langeslag's whistleblower and MHRA claims. The court of appeals affirmed all rulings, but the supreme court granted review only of the submission of Eddy's intentional-infliction-of-emotional-distress counterclaim.

Remand instructions

Reverse the judgment and remand to the district court for entry of judgment in accordance with the opinion.

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