## Facts

- KYMN, Inc. operated an AM radio station in Northfield, Minnesota; Wayne Eddy was its principal owner.
- Sharon Langeslag worked for KYMN as an outside sales representative beginning in 1996.
- Langeslag and Eddy had a hostile working relationship involving repeated arguments, shouting, and threats of litigation.
- Langeslag made reports to police and other authorities accusing Eddy of misconduct, including an allegation that he prevented her from leaving his office and a report concerning purported ticket scalping.
- In January 1998, Eddy was involved in a parking-lot incident that led to arrest and felony charges; Langeslag gave a police statement and later testified at Eddy’s criminal trial, which ended in a petty-misdemeanor conviction.
- After workplace disputes escalated, Eddy directed Langeslag to work from home; Langeslag later sued KYMN and Eddy for employment-related claims.
- Eddy counterclaimed for intentional infliction of emotional distress (IIED), alleging Langeslag’s conduct caused him severe emotional distress and stress-related physical problems.
- A jury found for Eddy on IIED and awarded $535,000; post-trial motions by Langeslag were denied, and the court of appeals affirmed.

## Issues

1. Whether Langeslag’s conduct—workplace arguments, threats of litigation, and allegedly false reports to police—could satisfy Minnesota’s “extreme and outrageous” element for IIED as a matter of law.
2. Whether, in a case involving complex medical issues, Eddy’s testimony and inconclusive medical records were sufficient to prove severe emotional distress and causation for IIED.

## Decision

- The Minnesota Supreme Court reversed and remanded, holding the IIED counterclaim should not have been submitted to the jury.
- The court held Langeslag’s alleged conduct did not, as a matter of law, rise to the level of “extreme and outrageous” conduct required for IIED.
- The court also held that, given complex medical issues and multiple potential causes, claimant testimony and inconclusive medical records were insufficient to establish causation between the challenged conduct and the alleged emotional distress.

## Legal Principles

- Minnesota IIED requires proof that the defendant engaged in extreme and outrageous conduct—behavior “utterly intolerable in a civilized community.”
- Ordinary workplace conflict, including heated arguments, threats to sue, and resort to law-enforcement processes, generally does not meet the “extreme and outrageous” threshold.
- When medical causation is complex, IIED requires competent evidence linking the alleged conduct to severe emotional distress; a claimant’s testimony coupled with ambiguous medical records is inadequate.
- Whether the evidence is legally sufficient to permit a jury to consider an IIED claim is a threshold question for the court.

## Conclusion

The court set aside the IIED verdict because the alleged workplace misconduct and reporting activity was not extreme and outrageous as required for IIED, and the proof of severe emotional distress and causation was legally insufficient where medical causation was complex and the supporting records were inconclusive.


Langeslag v. KYMN, Inc., 664 N.W.2d 860 (Minn. 2003)