To recover for intentional infliction of emotional distress, a plaintiff must show that (1) the defendant’s conduct was intentional or reckless, (2) the conduct was extreme and outrageous, (3) there was a causal connection between the wrongful conduct and the plaintiff’s emotional distress, and (4) the emotional distress was severe. Liability for this intentional tort is generated only by conduct that is very extreme.
The conduct must be not merely unjustifiable; it must rise to the level of “atrocious” and “beyond all possible bounds of decency,” such that it would cause an average member of the community to believe that it was outrageous. Examples of conduct that has been deemed sufficiently extreme and outrageous by Idaho courts include: an insurance company speciously denying a grieving widower’s cancer insurance claim while simultaneously impugning his character and drawing him into a prolonged dispute, recklessly shooting and killing someone else’s donkey that was both a pet and a pack animal, and real estate developers swindling a family out of property that was the subject of their lifelong dream to build a Christian retreat.