GTE Southwest, Inc. v. Bruce
998 S.W.2d 605 · Texas Supreme Court · 1999
Facts
Rhonda Bruce, Linda Davis, and Joyce Poelstra were employees at GTE Southwest, Inc.'s supply department in Nash, Texas. Their supervisor, Morris Shields, engaged in a pattern of constant humiliating and abusive behavior, including daily profanity, yelling, screaming, cursing, "charging" at them, and intentionally embarrassing them. Other employees had previously filed grievances against Shields for harassment at a different GTE facility, leading to investigations but no formal discipline. Despite the employees' complaints to GTE about Shields's conduct at Nash, GTE only issued a letter of reprimand, and the behavior continued. The employees eventually sought medical treatment for severe emotional distress caused by Shields's actions.
Procedural history
The trial court rendered judgment for the employees based on the jury verdict. The court of appeals affirmed this judgment. The case then came before the Supreme Court, which affirmed the judgment of the court of appeals.
Issue
Can employees recover damages for intentional infliction of emotional distress based on a supervisor's extreme and outrageous workplace conduct, and is such a claim barred by the Texas Workers' Compensation Act?
Holding
Yes, the employees can recover damages for intentional infliction of emotional distress. The court held that the employees' injuries were not compensable under the Texas Workers' Compensation Act, and the supervisor's cumulative conduct was extreme and outrageous, supporting the jury's verdict.
Rule
The Texas Workers' Compensation Act does not bar claims for intentional infliction of emotional distress if the injuries are not compensable under the Act. Injuries from repetitive mental trauma, not caused by a particular exciting event, are not compensable under the Act. To prove intentional infliction of emotional distress, a plaintiff must show the defendant acted intentionally/recklessly, the conduct was extreme and outrageous, caused emotional distress, and the distress was severe. In the employment context, conduct must go beyond an ordinary employment dispute, and repeated or ongoing severe harassment should be evaluated as a whole to determine if it is extreme and outrageous. An employer is vicariously liable for a supervisor's intentional torts committed in the scope of employment or if the supervisor is a vice-principal.
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