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American Road Serv. Co. v. Inmon

Supreme Court of Alabama
118 L.R.R.M. (BNA) 2511, 394 So. 2d 361 (1980)
ELI5:

Rule of Law:

One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress. The conduct must be so outrageous in character and so extreme in degree as to go beyond all possible bounds of decency, and be regarded as atrocious and utterly intolerable in a civilized society.


Facts:

  • Robert F. Inmon worked as a claims supervisor for The American Road Service Company, a subsidiary of Ford Motor Credit Company.
  • Inmon's supervisor, Jim Wooley, instructed Inmon to falsify a damage report on a company car so Wooley could purchase it at a reduced price, which Inmon did.
  • Wooley then delayed payment for the vehicle for approximately four months, requiring Inmon to make several 'collection' calls.
  • After Inmon accepted a new position with a sister company, the offer was rescinded.
  • Wooley conducted an unusual audit of Inmon's files, and Inmon's immediate supervisor, Donald Brady, gave him a series of confusing and peremptory orders to travel.
  • Inmon was interrogated by an internal security officer and Wooley about an alleged kickback scheme, during which he was accused of mishandling files but was not allowed to see them.
  • Following the investigation, Brady gave Inmon the choice to either resign or be discharged from his employment.

Procedural Posture:

  • Robert F. Inmon sued The American Road Service Company in an Alabama trial court.
  • The trial court instructed the jury on the law of outrageous conduct, and the jury returned a verdict in favor of Inmon for $25,000.
  • The trial court entered a judgment based on the jury's verdict.
  • The American Road Service Company's post-judgment motions, including a motion for judgment notwithstanding the verdict, were denied by the trial court.
  • The American Road Service Company, as appellant, appealed the judgment to the Supreme Court of Alabama.

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Issue:

Does Alabama law recognize a cause of action for the intentional or reckless tort of outrageous conduct causing severe emotional distress?


Opinions:

Majority - Justice Beatty

Yes. Alabama law recognizes the tort of outrageous conduct, which holds a person liable if by extreme and outrageous conduct they intentionally or recklessly cause severe emotional distress to another. The court joins numerous other jurisdictions in adopting the standard from the Restatement (Second) of Torts § 46, moving away from the traditional 'parasitic' model where emotional damages were only recoverable if attached to another tort. This tort, however, is reserved for conduct that is truly atrocious and utterly intolerable in a civilized society; it does not cover mere insults, indignities, or petty oppressions. Applying this new standard to the present case, the court found that the defendant's conduct did not meet this high threshold. While the company's investigation and termination of Inmon may have been disorganized and humiliating, its actions—such as auditing files, questioning an employee, and ultimately terminating him—were within its legal rights and did not constitute extreme and outrageous behavior as a matter of law.


Dissenting in part - Justice Faulkner

No, on the application of the law to the facts. Justice Faulkner concurred with the majority's decision to formally recognize the tort of outrageous conduct in Alabama but dissented from the conclusion that Inmon should be denied recovery based on the facts presented.



Analysis:

This landmark case formally establishes the independent tort of intentional infliction of emotional distress (IIED), also known as the tort of outrage, in Alabama. By adopting the Restatement (Second) of Torts § 46, the court abandoned the old rule that damages for mental anguish were only recoverable as 'parasitic' to another recognized tort. However, in its very first application of the new tort, the court set an extremely high bar for what constitutes 'extreme and outrageous' conduct. The decision signals that while the cause of action now exists, successful claims will be difficult to prove, particularly in contexts like employment where one party inherently has a degree of power and certain legal rights over the other.

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