Alderson v. Bonner
132 P.3d 1261, 142 Idaho 733 (2006)
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Rule of Law:
A claim for intentional infliction of emotional distress (IIED) requires the plaintiff to prove not only that the defendant's conduct was extreme and outrageous, but also that the resulting emotional distress was so severe that no reasonable person could be expected to endure it. Emotional reactions such as embarrassment, fear, anger, and changes in daily habits, without evidence of a severely disabling emotional response, are insufficient to meet this high standard.
Facts:
- Gary Lynn Bonner was the work supervisor of JoDee Alderson, the mother of Katie and Kelli Alderson, and had a past romantic relationship with her that had deteriorated.
- Over several months in 1999 and 2000, Bonner secretly videotaped 16-year-old Katie Alderson and her mother, JoDee, at their residence.
- The videotapes, filmed at night through gaps in window blinds, depicted Katie and JoDee in various states of undress while engaging in private activities like getting dressed, exercising, and using the bathroom.
- Kelli Alderson, then 21, lived at this same residence with her mother and sister until the end of 1999, but she was not depicted in the videos.
- In June 2000, after Kelli had moved to a new house, Bonner was discovered prowling outside her residence at night while holding a video camera.
- Kelli had seen a figure's shadow outside her front door just before the police arrived and found Bonner in the driveway.
- As a result of Bonner's actions, Katie experienced embarrassment, shame, and fear, leading her to change clothes only in windowless rooms and have difficulty trusting males.
- Kelli testified that she developed trust issues, problems sleeping, and a general fear for herself and her children.
Procedural Posture:
- Katie Alderson and Kelli Alderson sued Gary Lynn Bonner in an Idaho trial court for various torts, including invasion of privacy and intentional infliction of emotional distress (IIED).
- A jury returned verdicts in favor of both plaintiffs, awarding Katie $100,000 for IIED and $40,000 for invasion of privacy, and Kelli $40,000 for IIED and $15,000 for invasion of privacy.
- Bonner filed a post-trial motion for judgment notwithstanding the verdict (jnov), arguing the evidence was insufficient to support the verdicts.
- The trial court denied Bonner's motion with respect to the IIED and invasion of privacy claims.
- Bonner, as appellant, appealed the trial court's denial of his motion to the Court of Appeals of Idaho.
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Issue:
Does a plaintiff's emotional distress, consisting of fear, embarrassment, anger, and subsequent changes in daily habits but not rising to a disabling level, meet the 'severe' emotional distress element required for a claim of intentional infliction of emotional distress?
Opinions:
Majority - Lansing, J.
No. To be actionable as intentional infliction of emotional distress, the distress must be so severe that no reasonable person could be expected to endure it. Although Bonner's conduct toward Katie was extreme and outrageous, neither Katie's nor Kelli's resulting emotional distress rose to the required level of severity. The court reasoned that liability for IIED is reserved for cases involving a 'severely disabling emotional response,' not for the 'transient and trivial emotional distress' that is a part of life. While Kelli experienced trust issues, fear, and sleep problems, and Katie felt embarrassment, fear, and altered her daily habits, their reactions did not constitute the type of severe or disabling emotional turmoil required by law. The court contrasted their suffering with cases where severity was found, such as diagnoses of post-traumatic stress disorder or plaintiffs being swindled out of a 'life's plan.' The court concluded that while their emotional discomfort was compensable under their invasion of privacy claims, it was not severe enough to support the separate tort of IIED.
Analysis:
This decision significantly clarifies the high threshold for the 'severe emotional distress' element in IIED claims in Idaho. It establishes that even in the face of unquestionably outrageous conduct, a plaintiff cannot prevail on an IIED claim without demonstrating an emotional response that is profoundly debilitating, rather than just significant fear, anger, or lifestyle adjustments. The ruling reinforces the tort's role as a remedy for only the most extreme emotional injuries, preventing it from overlapping with lesser torts like invasion of privacy which compensate for more moderate emotional harm. This precedent forces future courts and litigants to carefully distinguish between profound, disabling psychological injury and other forms of mental anguish when pursuing IIED claims.
