## Facts

- An elementary school vice principal asked a Delaware state trooper serving as a school resource officer, David Pritchett, to question a fifth-grade student (A.B.) about alleged theft from another student.
- A.B. accused eight-year-old Anthony Hunt of the theft.
- Although Pritchett was nearly certain A.B. was the actual offender, he had Hunt summoned and escorted him to a room where A.B. was present, without the vice principal’s knowledge or consent.
- Pritchett closed the door, questioned Hunt in a harsh or aggressive tone, and repeatedly asserted his police authority.
- Pritchett told Hunt approximately eleven times that he could arrest him and send him to jail if he lied.
- Hunt became visibly distressed during the encounter; A.B. ultimately confessed to taking the money.
- Hunt later reported the incident to his mother and was withdrawn from school for roughly eighteen months, during which he was homeschooled.
- Hunt (through his mother) sued the State and Pritchett, asserting claims under 42 U.S.C. § 1983 and Delaware tort law, including intentional infliction of emotional distress (IIED), false imprisonment, and battery.
- The trial court granted summary judgment for defendants on the remaining claims; Hunt appealed.

## Issues

1. Whether the evidence permitted a reasonable jury to find Pritchett’s conduct toward an eight-year-old student “extreme and outrageous” and causative of severe emotional distress sufficient to support IIED.
2. Whether the record created a triable issue of false imprisonment based on escorting and questioning Hunt in a closed room.
3. Whether the record created a triable issue of battery absent harmful or offensive touching.
4. Whether Pritchett was entitled to qualified immunity on the § 1983 claim because no clearly established federal right was violated.

## Decision

- The Delaware Supreme Court affirmed in part and reversed in part the summary judgment.
- The court held that a jury could find Pritchett’s conduct extreme and outrageous toward a vulnerable child under his authority and reinstated the IIED claim.
- The court found the evidence of distress (including visible fear and later removal from school) sufficient to allow a jury to determine whether distress was “severe.”
- The court affirmed summary judgment on the battery claim because the record did not show harmful or offensive touching.
- The court affirmed summary judgment on at least part of the false imprisonment and § 1983 claims, concluding those theories did not proceed on the record and governing law to the same extent as the IIED claim.

## Legal Principles

- IIED requires conduct so extreme and outrageous that it exceeds all bounds of decency, and distress that a factfinder could regard as severe.
- Whether conduct is “extreme and outrageous” is context-dependent; a child’s age and vulnerability, and a defendant’s position of authority, are central to the analysis.
- A state actor’s intimidation of a child in a school setting—such as repeated threats of arrest and jail—can support an IIED claim even if related tort theories fail.
- Battery requires intentional harmful or offensive touching; psychological intimidation alone is insufficient.
- For § 1983, qualified immunity bars damages unless the defendant violated a clearly established federal right.

## Conclusion

The court held that an armed, uniformed school officer’s repeated threats to jail an eight-year-old during a closed-door interrogation could be found extreme and outrageous, requiring that the IIED claim be tried to a jury, while affirming dismissal of claims lacking required elements such as offensive touching and, in part, clearly established constitutional violations.


Hunt v. State, 69 A.3d 360 (Del. 2013)