Woodruff v. Miller
64 N.C. App. 364, 1983 N.C. App. LEXIS 3257, 307 S.E.2d 176 (1983)
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Rule of Law:
Maliciously disseminating information about a person's past, even if truthful and publicly available, for the sole purpose of personal spite and harassment can constitute 'extreme and outrageous conduct' sufficient to support a claim for intentional infliction of emotional distress.
Facts:
- The plaintiff had a past minor criminal transgression for which he had long since paid his debt to society.
- At the time of the defendant's actions, the plaintiff's record was not being considered or reviewed by any person or agency.
- The defendant, motivated by a 'consuming animus' and spite, obtained copies of the plaintiff's old criminal records.
- The defendant used 'truculent, vindictive methods' to circulate the records.
- While circulating the records, the defendant outrageously compared the plaintiff, a minor transgressor, to dangerous criminals who have escaped apprehension.
- The defendant's actions caused the plaintiff severe distress, including being unable to sleep, a result in which the defendant took delight.
- The defendant's 'calculated, persistent plan' was for no purpose other than his own 'spiteful satisfaction' in disturbing, humiliating, and harassing the plaintiff.
Procedural Posture:
- The plaintiff sued the defendant in a trial court for intentional infliction of mental distress.
- A jury heard the case and rendered a verdict in favor of the plaintiff.
- The defendant moved for a judgment notwithstanding the verdict (JNOV).
- The trial court judge granted the defendant's motion, setting aside the jury's verdict and entering judgment for the defendant.
- The plaintiff, as appellant, appealed the trial court's entry of the JNOV to the intermediate appellate court.
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Issue:
Does a defendant's conduct of obtaining and vindictively circulating a plaintiff's old, minor criminal record, motivated solely by personal animosity and for the purpose of harassment, constitute 'extreme and outrageous conduct' for a claim of intentional infliction of emotional distress?
Opinions:
Majority - Phillips, Judge
Yes. The defendant's conduct constitutes 'extreme and outrageous conduct' sufficient for a claim of intentional infliction of emotional distress. The court found plenary evidence for all three elements of the tort: (1) extreme and outrageous conduct, (2) intent to cause severe emotional distress, and (3) causation of severe emotional distress. The defendant’s motivation of pure animosity and spite, the vindictive methods used to circulate the records, the outrageous comparison of the plaintiff to dangerous criminals, and his delight in the plaintiff's suffering all combined to form a calculated, persistent plan to harass and ruin the plaintiff. Such 'maliciously destructive and disruptive conduct' is properly regarded by the law as extreme and outrageous, and it is the jury's role to determine liability in such circumstances.
Analysis:
This decision clarifies that the tort of intentional infliction of emotional distress is highly context-dependent, focusing on the defendant's motive and the manner of their actions, not merely the substance of the information conveyed. It establishes that even the dissemination of truthful, public information can be actionable if done in an extreme and outrageous way with the intent to cause severe harm. The ruling reinforces the jury's role as the community's conscience in determining when conduct crosses the line from merely insulting to legally outrageous, thereby protecting individuals from calculated campaigns of personal harassment.
