California, United States of America
The following excerpt is from Christensen v. Superior Court, 2 Cal.Rptr.2d 79, 54 Cal.3d 868, 820 P.2d 181 (Cal. 1991):
We agree. "The law limits claims of intentional infliction of emotional distress to egregious conduct toward plaintiff proximately caused by defendant." (Miller v. National Broadcasting Co. (1986) 187 Cal.App.3d 1463, 1489, 232 Cal.Rptr. 668. Italics added, original italics omitted.) The only exception to this rule is that recognized when the defendant is aware of, but acts with reckless disregard of the plaintiff and the probability that his conduct will cause severe emotional distress
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