Richards v. U.S. Steel

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s Ill. state-court action alleging that defendant subjected plaintiff to emotional distress through various actions taken against her during her employment. Plaintiff’s allegations against defendant were insufficient to demonstrate “extreme or outrageous” behavior necessary to establish emotional distress claim, where: (1) her supervisors made comments about plaintiff’s lack of competency to perform her job; (2) one supervisor made insulting remark about plaintiff’s weight and dared plaintiff to call him insulting name; (3) one supervisor grabbed plaintiff’s radio off her chest to make call; and (4) two individuals in defendant’s human resources dept. made insensitive remarks to plaintiff about her complaints against her supervisor. Result may have been different had plaintiff proceeded under Ill. Human Rights Act, where said Act may have required different response from human resources personnel.