California, United States of America
The following excerpt is from Ledger v. Tippitt, 164 Cal.App.3d 625, 210 Cal.Rptr. 814 (Cal. App. 1985):
7 In Kiseskey v. Carpenters' Trust For So. California (1983) 144 Cal.App.3d 222, 229, 233, 192 Cal.Rptr. 492, defendant telephoned plaintiff saying: " 'You are a no good son of a bitch and if you don't resign the agreement and get in set with the union, you'll be put in the hospital.' ..." Later, defendant again telephoned, saying: " 'Since you do not seem to be concerned about your safety and well-being, maybe you will be concerned about the well-being of your wife and children.' " Plaintiff had a cause of action for intentional infliction of emotional distress. Note, however, that his wife, who apparently did not hear the threats, still could claim loss of consortium which accrued when her husband suffered severe emotional distress.
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