Tort of Outrage Elements
The Supreme Court has articulated the four elements necessary to prove this cause of action which is sometimes referred to as the tort of outrage:
(1) the conduct must be intentional or in reckless disregard of the probability of causing emotional distress;
(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 in question must be severe;
Swerdlick v. Koch, 721 A.2d 849, 862 (R.I. 1998).
Additionally, "at least some proof of medically established physical symptomatology" is required for a successful intentional infliction of mental distress action. Id. at 863.
"Psychic as well as physical injury claims must be supported by competent expert medical opinion regarding origin, existence and causation." Vallinoto v. DiSandro, 688 A.2d 830, 839 (R.I. 1997).