Is Supplying Someone's Name As a Suspect of Murder Constitute Extreme and Outrageous Conduct ?
In Layne v. Builders Plumbing Supply Co., 210 Ill. App. 3d 966, 973, 569 N.E.2d 1104, 155 Ill. Dec. 493 (1991), this court held that a statement to the police, which was alleged to be false, that the plaintiff harassed, assaulted, and verbally threatened a coworker did not rise to the level of extreme and outrageous conduct required to be actionable.
The Court said in that case:
"While it is not unlikely that defendant's alleged conduct created some distress and embarrassment for plaintiff and may have subjected plaintiff to some indignities, we do not believe the conduct was 'so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency'." Layne, 210 Ill. App. 3d at 973, quoting Public Finance Corp. v. Davis, 66 Ill. 2d 85, 90, 360 N.E.2d 765, 4 Ill. Dec. 652 (1976).
See also Balark v. Ethicon, Inc., 575 F. Supp. 1227, 1231 (N.D. Ill. 1983) (supplying the plaintiff's name to the FBI as a suspect in the Tylenol murders did not constitute extreme and outrageous conduct); Adams, 292 Ill. App. 3d at 39 (a false complaint to the police of criminal trespass to vehicle that resulted in the plaintiff's arrest was not extreme and outrageous conduct).