Harris v. Jones

In Harris v. Jones, 281 Md. 560, 380 A.2d 611 (1977), the Court of Appeals stated that, for the tort of intentional infliction of emotional distress: (1) the conduct must be intentional or reckless; (2) the conduct must be extreme and outrageous; (3) there must be a causal connection between the wrongful conduct and the emotional distress; (4) the emotional distress must be severe. (Harris, 281 Md. at 566.) Conduct is deemed outrageous and extreme "only where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community." (Id. at 567.)