Nagata v. Quest Diagnostics Inc.
United States District Court for the District of Hawai'i
303 F. Supp. 2d 1121 (2004)
After Nagata's (plaintiff) urine sample tested inconsistent with human urine on a workplace drug test, Quest Diagnostics (defendant) discovered in February 1999 that it had used incorrect testing procedures for a period including Nagata's test, but did not inform Nagata's employer of the error until January 2001, nearly two years later; Nagata had been fired based on the faulty result and, in the meantime, suffered depression, substance abuse, and suicidal ideation before finally being offered his job back once the error was disclosed. Nagata sued Quest for intentional infliction of emotional distress based on its two-year delay in reporting the error, and Quest moved for summary judgment.
Whether, to maintain a claim for intentional infliction of emotional distress, a plaintiff must establish that the conduct was intentional or reckless, was outrageous, and caused extreme emotional distress to another.