Computer Publications, Inc. v. Welton

Summary

The Supreme Court of Oklahoma reviewed a judgment awarding Alysia Beth Welton damages for intentional infliction of emotional distress arising from Cameron Craig's prolonged harassment after their consensual relationship and employment ended. The court held that sufficient evidence supported submission of the extreme-and-outrageous-conduct and severe-emotional-distress elements to the jury, vacated the contrary portion of the Court of Civil Appeals' opinion, and affirmed the trial court's judgment.

Holdings

1. The evidence was not entirely absent on the extreme-and-outrageous-conduct element; Craig's persistent harassment over approximately two years could reasonably support a finding of conduct beyond all possible bounds of decency. The trial court therefore properly denied the directed-verdict motion on this element.
2. The evidence was not entirely absent on the severe-emotional-distress element, and the trial court properly allowed the claim to go to the jury.
3. The trial court acts as a gatekeeper on whether conduct may be considered extreme and outrageous and whether severe emotional distress can be found; when reasonable persons may differ, the jury determines whether the conduct was sufficiently outrageous and whether severe distress in fact existed.

Questions Presented

1. Whether Craig's conduct, viewed in the light most favorable to Welton, was sufficiently extreme and outrageous to permit submission of her intentional-infliction-of-emotional-distress claim to the jury.
2. Whether the evidence was sufficient to permit the jury to find that Welton suffered severe emotional distress.
3. Whether the trial court properly denied Craig's motion for directed verdict.

Disposition

vacated