Is a decision made by a human resources manager sufficient to support a claim of intentional infliction of emotional distress?

Personnel decisions "[are] insufficient to support a claim of intentional infliction of emotional distress, even if improper motivation is alleged." Janken v. GM Hughes Elecs. , 46 Cal. App. 4th 55, 80, 53 Cal.Rptr.2d 741 (1996) ("A simple pleading of personnel management activity is insufficient to support a claim of intentional infliction of emotional distress, even if improper motivation is alleged."). However, personnel management actions would be unlawful if motivated by prohibited discriminatory considerations. Id. at 79, 53 Cal.Rptr.2d 741.