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Va. 366, 373, 377 S.E.2d 412, 415 (1989); see also Weth v.
O'Leary, __ F. Supp. 2d. __, 2011 WL 2693178, at *5 (E.D. Va.
July 11, 2011) (―Intentional infliction of emotional distress is
a highly disfavored claim in the Fourth Circuit . . . .‖). In
order to recover on such claim, a plaintiff must prove:
(1) ―the wrongdoer‘ s conduct was intentional or reckless‖;
(2) ― the conduct was outrageous and intolerable‖; (3)
―there was a causal connection between the wrongdoer 's
conduct and the emotional distress‖; and (4) ― the emotional
distress was severe.‖
Hatfill v. The New York Times Co., 532 F.3d 312, 32 5-26 (4th
Cir. 2008) (quoting Womack v. Eldridge, 215 Va. 338 , 342, 210
S.E.2d 145, 148 (1974)).
Here, a review of the Complaint reveals that Plaint iff
fails to plead facts sufficient to state a plausibl e right to
relief on this ground, most notably by her failure to allege any
facts demonstrating ―outrageous and intolerable‖ co nduct. See
Russo v. White, 241 Va. 23, 27, 400 S.E.2d 160, 162 (1991)
(indicating that a plaintiff must demonstrate that ―the 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‖); Harris v. Kreutzer, 271 Va. 188, 204, 624 S.E.2d
24, 33-34 (2006) ( ―Insensitive and demeaning conduct does not
equate to outrageous behavior ,‖ and allegations of ― tortious or
even criminal ‖ in tent are likewise insufficient to establish Jump to an indexed page (39 of 39)