Ford v. Revlon, Inc.
Arizona Supreme Court
734 P.2d 580 (1987)
Leta Ford (plaintiff) was sexually harassed by her supervisor Braun (defendant) at Revlon (defendant), reporting the misconduct repeatedly to Revlon personnel over more than nine months while developing serious physical symptoms from the stress, yet Revlon merely told Braun he would be closely monitored and did not formally censure him until over a year after the harassment began, with Braun terminated only after Ford later attempted suicide. A jury found Braun liable for assault and battery but not intentional infliction of emotional distress, while finding Revlon liable for intentional infliction of emotional distress but not assault and battery; the court of appeals reversed Revlon's liability, reasoning that since its agent Braun wasn't found liable for that tort, Revlon as principal couldn't be either, and the Arizona Supreme Court granted review.
Whether an employer may be independently liable for intentional infliction of emotional distress against an employee.