Is intentional infliction of emotional distress a workers' compensation claim?

We held in Cole v. Fair Oaks Fire Protection Dist. (1987) 43 Cal.3d 148, 160, 233 Cal.Rptr. 308, 729 P.2d 743, that the exclusive remedy provisions of the workers' compensation law preclude a civil claim for intentional infliction of emotional distress if the employer's actions giving rise to the claim were "a normal part of the employment relationship." The Court of Appeal did not decide whether Cole applies here, and defendants did not raise this issue in their petition for review. Accordingly, we also do not reach the issue.