Jackson v. City of Wooster Board of Education
29 Ohio B. 254, 504 N.E.2d 1144, 29 Ohio App. 3d 210 (1985)
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Rule of Law:
To recover for intentional infliction of emotional distress, a plaintiff must prove the actor intended or knew their actions would cause serious emotional distress, the conduct was extreme and outrageous, it proximately caused psychic injury, and the mental anguish was severe; for negligent infliction, the emotional distress must also be severe and debilitating.
Facts:
- On April 3, 1984, Erik Jackson, an eighth-grade student, attended his regular physical education class taught by William McConnell at Edgewood Junior High School.
- McConnell had a known rule allowing only one towel per student after showering due to short supply.
- After showering, McConnell gave Erik a towel, but then observed Erik take a second towel.
- McConnell reminded Erik of the one-towel rule and told him to put the towel back, but Erik responded with laughter and non-compliance.
- McConnell ordered Erik, who was still naked, to do twenty-five push-ups, which was McConnell's standard punishment for comparable defiant behavior.
- Erik asked if he could get dressed before doing the push-ups, but McConnell told him "just do the push-ups" and continued supervising other students.
- While Erik was doing push-ups, someone told him to "make sure his penis touched the floor"; Erik claimed McConnell made the statement, but McConnell denied it, and a student witness testified it was another student.
- That night, Erik told his mother about the incident.
Procedural Posture:
- Walter, Constance, and Erik Jackson filed a complaint against the City of Wooster Board of Education and William McConnell on April 26, 1984, in the Wayne County Court of Common Pleas, seeking damages for negligent or intentional infliction of emotional distress.
- A bench trial was held on February 28, 1985.
- The trial court found that McConnell had not acted outrageously, had not intended to emotionally injure Erik, and did not cause any serious emotional distress to Erik.
- The trial court ruled in the defendants' favor and dismissed the Jacksons' complaint with prejudice.
- Walter, Constance, and Erik Jackson (appellants) appealed the judgment of the Wayne County Court of Common Pleas.
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Issue:
Does a junior high school teacher's act of requiring a naked student to do push-ups for violating a locker room rule, coupled with an alleged crude remark by someone, constitute intentional or negligent infliction of emotional distress when the student claims psychological harm?
Opinions:
Majority - Mahoney, P.J.
No. A junior high school teacher's act of requiring a naked student to do push-ups for violating a locker room rule, even with an alleged crude remark by someone, does not, under these facts, constitute intentional or negligent infliction of emotional distress because the elements for such claims were not proven. The court affirmed the trial court's findings that the Jacksons failed to prove three of the four elements required for intentional infliction of emotional distress under Pyle v. Pyle. First, the record indicated McConnell's intent was to ensure discipline through punishment, not to emotionally injure Erik, and there was no indication he knew or should have known his act would cause such injury. Second, McConnell's conduct was not deemed "extreme and outrageous" as to go "beyond all possible bounds of decency" or be "utterly intolerable in a civilized community." This was particularly true given the trial court's finding, supported by testimony, that McConnell did not make the crude remark and merely denied Erik's request to dress first in a busy locker room environment. Finally, Erik did not suffer "serious" emotional distress; the evidence, including his continued participation in school and extracurricular activities, suggested his injury amounted to "hurt feelings" rather than severe emotional distress required by Yeager v. Local Union 20 and Reamsnyder v. Jaskolski. Regarding negligent infliction of emotional distress, the court similarly found that Erik failed to establish "severe and debilitating" emotional distress as required by Paugh v. Hanks, thus upholding the trial court's denial of recovery under this theory as well.
Analysis:
This case reinforces the high burden on plaintiffs to prove claims of intentional or negligent infliction of emotional distress, particularly in the context of school disciplinary actions. It demonstrates that courts afford educators significant discretion in maintaining classroom and school order, and that actions perceived as embarrassing or harsh will not automatically meet the "extreme and outrageous" or "severe and debilitating" thresholds for these torts. The ruling underscores the necessity of objective evidence of severe emotional harm and a clear intent to inflict distress, rather than mere disciplinary intent, to succeed in such claims. This precedent likely serves to limit litigation stemming from typical, albeit sometimes regrettable, school disciplinary measures.
