## Facts

- William R. Harris, a 26-year-old General Motors (GM) employee with a lifelong stutter and a preexisting nervous condition, worked at a GM automobile assembly plant.
- For roughly five months in 1975, Harris’s supervisor, H. Robert Jones, repeatedly mocked Harris’s stutter, allegedly approaching him more than thirty times and verbally and physically mimicking his speech impediment in a derisive manner.
- Harris alleged Jones knew of the stutter and Harris’s sensitivity about it, yet continued the ridicule with the intent to cause emotional harm.
- Harris sought a departmental transfer; Jones allegedly labeled him a “troublemaker” and chastised him for pursuing a grievance.
- Other employees, including other supervisors, also mimicked Harris’s stutter in the workplace.
- Harris testified he felt humiliated and “shaken up” and claimed the conduct aggravated his nervous condition and worsened his stutter.
- During the period at issue, Harris visited his physician once and continued on the same medication he had been taking for years.

## Issues

1. Whether Maryland recognizes intentional infliction of emotional distress (IIED) as an independent tort.
2. Whether Harris proved the elements of IIED, particularly (a) a causal connection between defendants’ conduct and his distress and (b) emotional distress sufficiently severe to be legally actionable.

## Decision

- The Court of Appeals of Maryland recognized IIED as an independent cause of action and adopted a four-element test derived from Restatement (Second) of Torts § 46.
- The court affirmed the reversal of the jury verdict for Harris because the evidence did not establish severe emotional distress and did not adequately show that defendants’ conduct caused a substantial aggravation of Harris’s condition.
- As a result, Harris took no recovery on the IIED claim despite the jury’s compensatory and punitive awards at trial.

## Legal Principles

- IIED is actionable in Maryland as an independent tort.
- A plaintiff must prove all four elements to impose IIED liability: (1) intentional or reckless conduct; (2) extreme and outrageous conduct; (3) causation; and (4) severe emotional distress.
- Liability is reserved for exceptional cases; the law does not provide relief for mere insults, rough language, or unkind acts absent proof meeting the required threshold.
- “Severe” distress requires more than transient humiliation or upset; the evidence must show distress so extreme that a reasonable person could not be expected to endure it.
- Where a plaintiff has preexisting conditions or other stressors, proof of causation must show more than speculative or weak linkage between the defendant’s conduct and the claimed emotional harm.

## Conclusion

Maryland adopted IIED and its four-element framework, but the court denied relief because Harris’s proof did not show legally severe emotional distress or a sufficiently supported causal connection between the workplace ridicule and any material worsening of his condition.


Harris v. Jones, 281 Md. 560, 380 A.2d 611 (Md. 1977)