Conn. Civ. Jury Instr. 3.12-1

The plaintiff alleges a claim for intentional infliction of emotional distress. The plaintiff alleges

specific ways in which the defendant engaged in intentional infliction of emotional distress as

follows: <Insert allegations of the complaint here.>

There are four elements that must be established for a finding of intentional infliction of

emotional distress:

1. the defendant intended to inflict emotional distress, or that the defendant knew or

should have known that emotional distress was the likely result of the defendant’s

conduct;

2. the conduct was extreme and outrageous;

3. the conduct was the cause of emotional distress experienced by the plaintiff; and

4. the emotional distress sustained by the plaintiff was severe.

To find that the defendant’s conduct was extreme and outrageous, the plaintiff must prove that

the defendant’s conduct exceeded all bounds usually tolerated by decent society. Only where the

defendant’s conduct has been so outrageous in character, and so extreme in degree, as to go

beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in

a civilized community may you find that the conduct was extreme and outrageous. Generally,

for the defendant’s actions to be considered extreme and outrageous, the telling of the facts to an

average member of the community would arouse one’s resentment against the actor, and lead

one to exclaim, Outrageous! Conduct by the defendant that is merely insulting, displays bad

manners or results in hurt feelings is not sufficient to prove a claim for intentional infliction of

emotional distress. Even if the defendant was wrongfully motivated in subjecting the plaintiff to

emotional distress, wrongful motivation by itself does not meet the standard for intentional

infliction of emotional distress; rather, it is the act itself which must be outrageous.

To find that the emotional distress sustained by the plaintiff was severe, you must find that the

plaintiff’s mental distress was of a very serious kind. The distress inflicted must be so severe

that no reasonable person could be expected to endure it. The intensity and the duration of the

distress are factors to be considered in determining its severity. You may also consider whether

the plaintiff sought medical or psychological treatment.

For the plaintiff to prevail on a claim of intentional infliction of emotional distress, you must find

that the plaintiff has proved all of the elements of intentional infliction of emotional distress.

If you find that the plaintiff has not proved all of the elements of intentional infliction of

emotional distress, then you will return a defendant’s verdict on this count.