Littlefield v. McGuffey
954 F.2d 1337 (1992)
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Rule of Law:
Under Illinois common law, a plaintiff is not required to allege or prove a physical manifestation of emotional distress to recover for the tort of intentional infliction of emotional distress.
Facts:
- Susanne Littlefield met landlord Malcolm McGuffey, completed a rental application for an apartment, and gave him a $280 security deposit.
- McGuffey gave Littlefield a key, and she, her family, and friends began cleaning, painting, and moving belongings into the apartment over the next two weeks.
- Bruce Collins, Littlefield's boyfriend and the father of her daughter, who is not of the same race as Littlefield, went to give McGuffey a check for carpet installation.
- Upon realizing Collins's race and his relationship to Littlefield and her daughter, McGuffey became agitated and informed Collins that the apartment had been rented to someone else.
- McGuffey then called Littlefield, told her she could not rent the apartment, said he had changed the locks, and put her belongings on the porch.
- Over the next week, McGuffey made numerous harassing and racist phone calls to Littlefield and her sister, Kathleen Gutierrez, in which he claimed to be a KKK member and used racial slurs.
- McGuffey later located Littlefield's new residence and taped a napkin to her door with a racist death threat against Bruce Collins.
Procedural Posture:
- Susanne Littlefield sued Malcolm McGuffey in the U.S. District Court for the Northern District of Illinois, alleging violations of federal housing laws and intentional infliction of emotional distress under Illinois state law.
- A jury found McGuffey liable on all claims.
- The jury awarded Littlefield $50,000 in compensatory damages and $100,000 in punitive damages.
- McGuffey moved for a judgment notwithstanding the verdict or, alternatively, for a new trial.
- The district court denied both of McGuffey's motions and entered judgment on the verdict.
- McGuffey (appellant) appealed the judgment and the award of attorney's fees to the U.S. Court of Appeals for the Seventh Circuit.
- Littlefield (appellee) filed a cross-appeal challenging the district court's denial of a fee multiplier.
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Issue:
Does a plaintiff's claim for intentional infliction of emotional distress under Illinois law fail if the plaintiff does not provide evidence of medically significant, physical manifestations of that distress?
Opinions:
Majority - Harlington Wood, Jr.
No. Under Illinois law, a plaintiff is not required to prove a physical manifestation of emotional distress to recover for the tort of intentional infliction of emotional distress. The court's reasoning is based on established Illinois Supreme Court precedent. In cases such as McGrath v. Fahey and Corgan v. Muehling, the Illinois Supreme Court established that the tort comprises only three elements: 1) extreme and outrageous conduct, 2) intent to cause (or high probability of causing) severe emotional distress, and 3) the conduct in fact causing severe emotional distress. Medically significant, physical manifestation is not an element of the tort. Therefore, the district court did not err in admitting Littlefield's testimony about her fear and anxiety, even without accompanying physical symptoms.
Analysis:
This decision reaffirms for federal courts applying Illinois law that the tort of intentional infliction of emotional distress focuses on the outrageousness of the defendant's conduct and the severity of the plaintiff's psychological harm, not on physical symptoms. It clarifies that a defendant's campaign of harassment following an act of housing discrimination can independently support a substantial emotional distress claim. The case also solidifies the procedural rule in the Seventh Circuit that the defendant, not the plaintiff, bears the burden of introducing evidence of their own financial state if they wish to mitigate a punitive damages award, preventing defendants from benefiting from obstructing discovery about their net worth.
