In Alcorn v. Anbro Engineering, Inc. (1970) 2 Cal. 3d 493, 86 Cal. Rptr. 88, 468 P.2d 216, the Supreme Court held that an employee had sufficiently alleged intentional infliction of emotional distress because his supervisor shouted racial epithets and fired him. The court found it significant that the person harassing the plaintiff was "standing in a position or relation of authority over plaintiff." (Id. at p. 498.)