Section 23 Intentional Infliction of Emotional Distress

LibraryProf Liability 2005

The unwieldy theory of intentional infliction of emotional distress may be necessary for pleading if the facts show any conduct amounting to:

  • cover-up
  • failure to investigate allegations; or
  • retaliation

Gibson v. Brewer, 952 S.W.2d 239, 249 (Mo. banc 1997).

In Gibson, the Supreme Court did not bar such a claim, but found only that it was not adequately pled. Id. at 249. It was discussed again in Weaver v. African Methodist Episcopal Church, Inc.,54 S.W.3d 575 (Mo. App. W.D. 2001), in which the...

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