Reagan v. Rider

POLLITT, Judge.

Ten years ago the Court of Appeals, in Harris v. Jones, 281 Md. 560, 380 A.2d 611 (1977), affirmed the holding of this Court, in Jones v. Harris, 35 Md.App. 556, 371 A.2d 1104 (1977), recognizing intentional infliction of emotional distress as an independent tort in Maryland. The Court of Appeals, noting that 37 jurisdictions appeared then to have recognized the tort as a valid cause of action, adopted the reasoning of the Supreme Court of Virginia in Womack v. Eldridge, 215 Va. 338, 210 S.E.2d 145 (1974), holding that four elements must coalesce to impose liability for…