In Creditwatch, Inc. v. Jackson, 157 S.W.3d 814, 817 (Tex. 2005), a former supervisor made lewd advances toward a woman after her employment had been terminated. Id. at 816. When she rebuffed his advances, the supervisor refused to give her a reference letter. Id. at 817. The supervisor also required a current employee--who had invited her financially-strapped former co-worker to live in her home--to evict the woman if the employee wanted to keep her job. Id. The supreme court held that this behavior was not extreme and outrageous under the required standard for intentional infliction of emotional distress. Id. at 817-18. Whether conduct is extreme and outrageous for the purpose of intentional infliction of emotional distress generally is a question of law. Such claims are submitted to the jury only when reasonable minds may differ. Id. Intentional infliction claims do not extend to ordinary employment disputes. Id. Certain post-termination conduct may constitute intentional infliction, but "callous, meddlesome, mean-spirited, officious, overbearing, and vindictive" conduct is not enough. Id. The conduct must "go beyond all possible bounds of decency" and "be regarded as atrocious, and utterly intolerable in a civilized community." Id. The supreme court has gone so far as to say that "except in circumstances bordering on serious criminal acts," even claims "stemming from heinous acts . . . rarely have merit as intentional infliction claims." See id. at 818. The supreme court held that the act of the plaintiff's former employer in orchestrating a post-termination eviction of the plaintiff was "callous, meddlesome, mean spirited, officious, overbearing, and vindictive--but not '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.'" The court stated that "we certainly understand judicial reticence to dismiss claims like this one stemming from heinous acts" but that "such acts will rarely have merit as intentional infliction claims," "except in circumstances bordering on serious criminal acts."