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Snyder v. Sunshine Dairy
Citations: 742 P.2d 57; 87 Or. App. 215Docket: A8508-04785 CA A39969
Court: Court of Appeals of Oregon; September 9, 1987; Oregon; State Appellate Court
William J. Snyder appeals a judgment that dismissed his complaint against Sunshine Dairy and its representatives for failing to state sufficient facts for a claim of intentional infliction of emotional distress. Snyder, who had been employed by the defendant since 1956, alleged that in 1983, he faced harassment and intimidation intended to compel him to resign. He claimed a systematic course of conduct aimed at causing him extreme emotional distress. The legal standard for intentional infliction of emotional distress requires the defendant's actions to be an extraordinary transgression of socially tolerable conduct. The Court referenced prior cases (Hall v. The May Dept. Stores, Patton v. J.C. Penney Co.) to outline that the means of inflicting distress must also be extraordinary and properly pleaded. The Court found that Snyder's allegations, which included excessive supervision, unjustified reprimands, and various criticisms of his work performance, did not meet this threshold. Specific grievances Snyder raised included inconsistent task assignments, baseless reprimands, unjust accusations of damage, public ridicule, excessive surveillance, and being assigned menial tasks beyond his usual responsibilities. The Court concluded that even if these allegations were proven, they did not constitute an extraordinary transgression of socially acceptable conduct, thus affirming the dismissal of his complaint.