Law v. Harris
295 Ga. App. 628, 2009 Fulton County D. Rep. 117, 673 S.E.2d 14 (2009)
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Rule of Law:
For a claim of intentional infliction of emotional distress to be successful, the defendant's conduct must be so extreme and outrageous that it goes beyond all possible bounds of decency, and is regarded as atrocious and utterly intolerable in a civilized community. Conduct that is merely rude, insulting, or upsetting is insufficient to meet this high legal standard.
Facts:
- Ardie Bell Law was a long-time member of Sardis Presbyterian Church and was the manager of the church's food bank.
- Law alleged that the church's pastor, Harold Harris, was verbally abusive, humiliated her in front of other church members, and threatened to take over the food bank.
- During an April 6, 2005 meeting, church leaders, including Pastor Harris, demanded that Law return the keys to the church, remove all food bank property, and cease its operations.
- The next day, a church deacon, George Fields, confronted Law in the presence of others and demanded she surrender the church keys immediately.
- Law characterized the behavior of the church leaders as rude and "just plumb ugly."
Procedural Posture:
- Ardie Bell Law sued Sardis Presbyterian Church, its pastor, and one of its deacons in a Georgia trial court, alleging intentional infliction of emotional distress.
- The defendants filed a motion for summary judgment, arguing the alleged conduct was not legally sufficient to support the claim.
- The trial court granted the defendants' motion for summary judgment.
- Ardie Bell Law (appellant) appealed the trial court's decision to the Court of Appeals of Georgia, with the church and its leaders as appellees.
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Issue:
Does a church's conduct, including being verbally abusive, humiliating a member, demanding the return of church keys, and ordering the closure of a food bank she managed, rise to the level of 'extreme and outrageous' conduct required to sustain a claim for intentional infliction of emotional distress?
Opinions:
Majority - Johnson, Presiding Judge.
No, the church's conduct does not rise to the level of 'extreme and outrageous' conduct required for a claim of intentional infliction of emotional distress. To sustain such a claim, the alleged conduct must be so outrageous in character and extreme in degree as to go beyond all possible bounds of decency and be regarded as atrocious and utterly intolerable. The court determined that the alleged actions of the church leaders—being verbally abusive, humiliating Law, demanding the return of keys, and shutting down the food bank—did not meet this high threshold. The law does not provide a remedy for conduct that is merely rude, insulting, or, as Law described it, 'just plumb ugly.' Therefore, as a matter of law, the conduct was insufficient to support the claim.
Analysis:
This decision reinforces the extremely high bar for proving a claim of intentional infliction of emotional distress (IIED). It clarifies that actions perceived as verbally abusive, humiliating, or unfair within an organizational or community context are unlikely to be legally actionable as IIED unless they are truly atrocious. The case serves as a judicial gatekeeping mechanism, demonstrating that courts will dismiss such claims at the summary judgment stage if the conduct does not shock the conscience, thereby preventing juries from deciding cases based on mere insults or hurt feelings.
