Caldor Inc v. Bowden 625 A.2d 959 (Md. 1993) Parties: Plaintiff – Caldor Inc. – National retail chain store Defendant –Samuel Bowden – sixteen-year-old employee of Caldor Inc, accused of stealing money and merchandise. Facts: Caldor’s loss prevention personnel accused Bowden of stealing money and merchandise. Bowden denied the claim. After being interrogated for multiple hours, Bowden was told if he signed a “voluntary statement” form, made restitution, and didn’t involve his parents, Caldor wouldn’t call the police. Out of fear, Bowden signed the form. He told his mother the next day what happened and they returned to the store, claiming that they wanted to see the videotape evidence of Bowden stealing the money and merchandise. The store manager (Mehan) refused and handcuffed Bowden and escorted him thought the lower level of the store out the front door. Procedural Posture: Bowden filed IIED suit against the D in the Circuit Court for Baltimore City. Jury found in favor of Bowden and awarded $25,000 in damages for IIED. Defendants filed for JNWV on the IIED claim. The circuit court granted the motion. Bowden appealed. Issue: Whether Bowden’s injury was severe enough for a claim for IIED? Holding: No. Ruling: The court affirms the circuit court’s granting of JNWV for the IIED claim. Rule: Four elements essential to establish intentional infliction of emotional distress: 1. The conduct must be intentional or reckless; 2. The conduct must be extreme and outrageous; 3. There must be a casual connection between the wrongful conduct and the emotional distress; 4. The emotional distress must be severe Legal Reasoning: Court focused on Bowden’s severity of distress. The court found that for emotional distress to be considered severe, it must be so acute that no reasonable man could be expected to endure it. The court reasoned that Bowden’s distress may have been just uncomfortable. None of the effects of Bowden’s emotional distress indicated that he had been severely disabled with prevented his ability to carry out his daily activities. Not only did Bowden continue his normal activities, but he got medical attention just before litigation started.