What is the test for a claim for emotional distress in a personal injury case?

Restatement 46 cmt. d; see also Contreras v. Crown Zellerbach, 88 Wash.2d 735, 565 P.2d 1173 (1977) (adopting cmt. d). It is not enough that the conduct was maliciously, tortiously or criminally intended.

Several factors bear on the determination whether the alleged conduct meets this standard:

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(1) the position occupied by the defendants;

(2) whether plaintiffs were particularly susceptible to emotional distress, and if defendant knew this fact;

(3) whether defendants' conduct may have been privileged under the circumstances;