Eddy v. Brown
1986 OK 3, 715 P.2d 74, 54 U.S.L.W. 2476 (1986)
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Rule of Law:
For conduct to be actionable as intentional infliction of emotional distress, it must be so extreme and outrageous as to be beyond all possible bounds of decency. For a claim of public disclosure of private facts, the disclosure must constitute 'publicity,' meaning communication to the public at large or to a group so large that the matter is substantially certain to become public knowledge.
Facts:
- Forrest E. Eddy was an employee of Texaco Inc. from 1968 until he quit in 1981.
- Following a union strike in 1980, Eddy's supervisors, John Brown and Dallas Wilson, allegedly engaged in a course of harassment against him.
- This harassment included ridiculing Eddy for his union activities, denying him vacation time, telling him he would never be promoted, and mishandling his workers' compensation claim.
- On one occasion, Brown and Wilson directed Eddy to read a safety bulletin aloud to co-workers, knowing his speech was impaired by medication, and then mimicked and ridiculed him.
- Texaco arranged for Eddy to undergo a psychiatric evaluation.
- Subsequently, Brown or Wilson informed a limited number of Eddy's co-workers that he had been sent for psychiatric evaluation.
Procedural Posture:
- Forrest E. Eddy filed suit against Texaco Inc., John L. Brown, Jr., and Dallas D. Wilson, Jr. in the district court (trial court) for the tort of outrage and invasion of privacy.
- The trial court granted summary judgment in favor of the employer defendants.
- Eddy (appellant) appealed the decision to the Court of Appeals.
- The Court of Appeals reversed the trial court's judgment and remanded the case for trial.
- The employer defendants (petitioners) petitioned the Oklahoma Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does an employer's course of conduct, consisting of workplace harassment, ridicule, and administrative frustrations, rise to the level of extreme and outrageous conduct required for the tort of outrage, and does the disclosure of an employee's psychiatric evaluation to a small group of co-workers constitute an invasion of privacy?
Opinions:
Majority - Opala, Justice
No. The employer's conduct, while inconsiderate and unkind, does not rise to the level of extreme and outrageous conduct required for the tort of outrage, and the disclosure of private medical information to a small group of co-workers does not constitute the 'publicity' required for an invasion of privacy claim. For intentional infliction of emotional distress, Oklahoma adopts the Restatement (Second) of Torts § 46, which requires conduct 'so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency.' The court reasoned that liability does not extend to 'mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities,' and that the 'rough-and-tumble atmosphere of the American oil refinery' must be considered. Regarding the invasion of privacy claim, the court found the disclosure did not meet the element of 'publicity.' Publicity requires communication 'to the public at large, or to so many persons that the matter must be regarded as substantially certain to become one of public knowledge.' Because the information about Eddy's psychiatric evaluation was only disclosed to a 'limited number of co-workers,' the disclosure was not sufficiently public to be actionable.
Analysis:
This decision establishes a very high threshold for plaintiffs to succeed on claims of intentional infliction of emotional distress in the employment context in Oklahoma. It signals that courts will act as gatekeepers, dismissing claims based on common workplace conflicts, management disputes, and even harsh treatment unless the conduct is truly atrocious. The ruling also narrowly construes the 'publicity' element of invasion of privacy, making it difficult for such claims to succeed based on intra-office communications, thereby protecting employers from liability over workplace gossip or disclosures to small groups of employees.
