First recognized as a cognizable cause of action in 1978, the tort is designed to provide a remedy to an individual who suffers severe emotional distress after being subjected to extreme and outrageous conduct by another who intends to cause that distress or does so recklessly.
The cause of action action has four elements: (1) extreme and outrageous conduct; (2) intent to cause, or disregard of a substantial probability of causing, severe emotional distress; (3) a causal connection between the conduct and [plaintiff's] injury; and (4) severe emotional distress.
Extreme and outrageous conduct is that which goes beyond all possible bounds of decency, so as to be regarded as atrocious, and utterly intolerable in a civilized community.
Brown v. Riverside Church in the City of N.Y., NY Slip Op 03927 (1st Dep't July 25, 2024)
