GTE Southwest, Inc. v. Bruce

In GTE Southwest, Inc. v. Bruce, 998 S.W.2d 605, 616, 42 Tex. Sup. Ct. J. 907 (Tex. 1999), three GTE employees were harassed for years by their supervisor's regular abuse, humiliation, and intimidation, which included persistent verbal and physical threats. Id. at 613-14. The Court concluded that, although occasional malicious and abusive incidents must often be tolerated in our society, "once conduct such as that shown here becomes a regular pattern of behavior and continues despite the victim's objection and attempt to remedy the situation, it can no longer be tolerated." Id. at 617. But it was not merely the regularity of the supervisor's conduct that led us to conclude that the conduct was extreme and outrageous as a matter of law; it was also its severity. Id. ("It is the severity and regularity of Shields's abusive and threatening conduct that brings his behavior into the realm of extreme and outrageous conduct.") As the Court stated, "being purposefully humiliated and intimidated, and being repeatedly put in fear of one's physical well-being at the hands of a supervisor is more than a mere triviality or annoyance." Id.