In City of Midland v. O'Bryant, 18 S.W.3d 209 (Tex. 2000), several former police officers sued their employer, the City of Midland, after the City notified them that it had reclassified their duties into civilian positions.
The court rejected the plaintiffs' claim, reasoning that an employer's decision to revise job descriptions, or to change the nature of compensation for certain positions, would not support the tort of intentional infliction of emotional distress.
Reclassifications of job positions are the type of business or employment decisions that an employer must have the latitude to make. Id. at 217.