S.E. v. BMO Harris National Bank Association

Plaintiffs filed an interlocutory appeal of the trial court’s dismissal of one count of their three-count amended complaint. The trial court dismissed plaintiff’s claim alleging intentional infliction of emotional distress by finding that it was barred by the two-year statute of limitations and/or failed to state a cause of action for IIED. The appellate court affirmed, finding that the trial court did not err when it concluded that the allegations contained in the complaint did not fall under the continuing-tort doctrine and that it could not conclude that the allegations met the stringent standards set by the courts for claims of intentional emotional distress. (McLAREN and MULLEN, concurring)