Appleton v. Board of Education

Citations: 254 Conn. 205; 757 A.2d 1059; 2000 Conn. LEXIS 274Docket: SC 16137

Court: Supreme Court of Connecticut; August 15, 2000; Connecticut; State Supreme Court

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The court examined whether the Appellate Court correctly determined that the defendants—Stonington Board of Education, Principal Cherri Rifenburg, and Assistant Principal Anthony Vacca—were not entitled to summary judgment on the plaintiffs' claims of intentional infliction of emotional distress and tortious interference with contractual relations. The plaintiff, a tenured teacher employed since 1963, faced scrutiny from Rifenburg starting in September 1995 due to an incident involving a student's attendance. Following concerns about the plaintiff's health and behavior, Rifenburg placed her on paid leave and initiated discussions involving various educational stakeholders. The plaintiff underwent two psychological evaluations that confirmed her ability to return to work. Ultimately, a memorandum of agreement was reached, leading to the plaintiff's resignation effective June 1996. After her resignation, the plaintiff filed a lawsuit alleging breach of contract, emotional distress, and tortious interference. The trial court granted summary judgment for the defendants on all counts. The Appellate Court subsequently upheld the breach of contract ruling but reversed the decisions on the emotional distress and tortious interference claims, prompting the defendants to appeal. The court granted certification to consider whether the Appellate Court's reversal was justified. The standards for reviewing summary judgment motions are established and will guide the court's decision.

Summary judgment is to be granted if the evidence, including pleadings and affidavits, shows no genuine issue of material fact, and the moving party is entitled to judgment as a matter of law. The trial court must assess evidence favorably towards the nonmoving party. The burden lies on the party seeking summary judgment to demonstrate the absence of genuine issues, while the opposing party must provide evidence to show such issues exist. In the context of a claim for intentional infliction of emotional distress, the court identified four necessary elements: (1) intent to inflict distress or knowledge that distress was likely; (2) conduct that is extreme and outrageous; (3) causation of the distress by the defendant’s conduct; and (4) severe emotional distress suffered by the plaintiff. The court determines whether conduct is extreme and outrageous, only leaving the issue to a jury if reasonable minds disagree. Liability requires conduct that is intolerable in a civilized community, with mere insults or bad manners insufficient to support a claim. In this case, the plaintiff's affidavit did not present a genuine issue regarding the defendants’ conduct, which included condescending remarks questioning her vision and reading ability, deemed insufficiently extreme or outrageous to warrant liability.

Rifenburg allegedly contacted the plaintiff's daughter, suggesting that the plaintiff had been behaving unusually and should take time off work. He also called the police, who escorted the plaintiff from the school to her car. The plaintiff claimed in her affidavit that she underwent two psychiatric evaluations at the board's request, was suspended, took a leave of absence, and ultimately resigned. However, these actions were deemed distressing but not extreme or outrageous enough to constitute intentional infliction of emotional distress under legal precedents. The court referenced previous cases affirming that escorting a discharged employee from premises is not unreasonable and does not amount to extreme conduct.

Additionally, defendants Rifenburg and Vacca argued that the Appellate Court incorrectly denied them summary judgment on the plaintiff's claim of tortious interference with her employment contract. They contended that the plaintiff did not suffer actual loss due to the alleged interference and failed to show they acted outside their employment for personal gain. The court agreed with the first point, emphasizing that to claim tortious interference, a plaintiff must demonstrate actual loss resulting from the interference, which is a critical component of the tort. The Appellate Court had upheld the trial court's finding that the plaintiff's resignation was voluntary, which was not contested for review, thus preventing any challenge to that conclusion.

In State v. Torrence, 196 Conn. 430 (1985), the court determined that the only relevant issues were those presented in the petition for certification. It was established that the plaintiff received full compensation according to her contract during her leave of absence and up to her resignation. Since she voluntarily resigned and was fully paid until that time, she did not demonstrate any actual loss due to the actions of Rifenburg and Vacca, which undermined her claim for tortious interference with contractual relations. Consequently, the Appellate Court's judgment was partially reversed, directing it to affirm the trial court's ruling on her claims for intentional infliction of emotional distress and tortious interference, while upholding the judgment in all other aspects. The justices concurred, noting that while the defendants' actions were found not actionable, they did not approve of the treatment the plaintiff received. The plaintiff's claims of lost earnings and career economic loss were countered by Rifenburg's affidavit, which confirmed that she was on a paid leave of absence, a fact the plaintiff did not dispute. Thus, the court accepted the defendants' assertion that the plaintiff was fully compensated until her resignation.