In the Lasater case, Nancy said that John deceived her for many years about his income and expenditures.  He lost his temper and yelled at her blaming her for the family’s financial plight.

This made her ill and gave rise to a claim in her lawsuit that John intentionally inflicted emotional distress on her.

The court said that one of the elements of this tort is extreme or outrageous conduct.  It found that John’s alleged actions, if true, did not rise to the level of extreme or outrageous conduct required.