MacArthur v. University of Texas Health Center at Tyler
Not available (1995)
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Rule of Law:
In the employment context, conduct such as harsh criticism, supervision, and discipline for an employee's actual carelessness or incompetence does not rise to the level of 'extreme and outrageous' conduct required to support a claim for intentional infliction of emotional distress under Texas law.
Facts:
- Cassandra MacArthur, a research lab technician, complained to her direct supervisor that department chair Dr. Richard Painter yelled and screamed at another female employee.
- Subsequently, MacArthur admittedly disposed of radioactive material in a regular wastebasket instead of the designated container.
- As a result of the radiation incident and other findings of incompetence, a Radiation Safety Committee, of which Painter was a member, indefinitely revoked MacArthur's privilege to use radiation.
- This revocation resulted in MacArthur's demotion, a salary reduction, and a warning that she would be terminated if her privileges were not reinstated by a certain date.
- In a separate incident, MacArthur attempted to adjust an incubator in Painter's lab, which resulted in the death of the cells inside.
- Following the incubator incident, Painter yelled at MacArthur to stay out of his laboratory and recommended to her supervisor that she be restricted from the facility.
- MacArthur resigned from her position approximately one week after receiving the termination warning.
Procedural Posture:
- Cassandra MacArthur filed suit against University of Texas Health Center at Tyler, Dr. Richard Painter, and Dr. Michael Wilson in the U.S. District Court for the Eastern District of Texas.
- The suit alleged claims for Title VII sex discrimination, First Amendment retaliation, and a state law claim of intentional infliction of emotional distress.
- The district court submitted these three claims to a jury via special interrogatories.
- The jury returned a verdict in favor of the defendants on the sex discrimination and First Amendment retaliation claims.
- The jury found in favor of MacArthur on the intentional infliction of emotional distress claim against Dr. Painter only, awarding her $65,000 in damages.
- The district court entered a final judgment based on the jury's verdict.
- MacArthur appealed the judgment concerning her Title VII retaliation claim, which she had not submitted to the jury for determination.
- Dr. Painter cross-appealed, challenging the sufficiency of the evidence supporting the jury's verdict against him for intentional infliction of emotional distress.
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Issue:
Does a supervisor's conduct, which includes yelling at an employee, accusing her of sabotage, and reporting her careless or incompetent performance of job duties, constitute 'extreme and outrageous' conduct sufficient to support a claim for intentional infliction of emotional distress under Texas law?
Opinions:
Majority - E. Grady Jolly
No, the supervisor's conduct does not constitute 'extreme and outrageous' conduct sufficient to support a claim for intentional infliction of emotional distress. To be actionable, conduct must be 'so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency.' The law does not protect against mere insults, indignities, or threats, and ordinary employment disputes involving supervision, criticism, and discipline do not meet this high standard. The court distinguished this case from precedents involving conduct like framing an employee for theft, finding that Painter's actions were responses to MacArthur's actual careless or incompetent performance of her duties. While Painter may have behaved intemperately or overreacted, his actions had a plausible basis and were within the realm of an employment dispute, not the kind of atrocious and utterly intolerable conduct required for this tort.
Analysis:
This decision reinforces the high threshold required to establish intentional infliction of emotional distress in an employment setting under Texas law, as interpreted by the Fifth Circuit. It clarifies that supervisory actions, even if harsh or rude, are generally not actionable as 'outrageous' when they are tied to an employee's actual performance deficiencies. The ruling protects an employer's authority to manage, discipline, and criticize employees without facing tort liability for emotional distress, thereby channeling such disputes toward statutory remedies like Title VII where applicable. This precedent makes it significantly more difficult for employees to succeed on IIED claims arising from typical, albeit unpleasant, workplace conflicts with superiors.
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