Swenson v. Northern Crop Insurance, Inc.

Caroline Swenson (plaintiff), a recovering alcoholic, was promoted from secretary to office manager at Northern Crop Insurance, Inc. (defendant), a promotion general manager John Krasbeth (defendant) opposed because he believed the role suited a man; Krasbeth then made repeated derogatory, sexist comments, threatened to replace her with a man, reorganized the office to demote her to a lower-paying clerk position, gave two new positions to men without letting her apply because of her sex, and began avoiding and refusing to speak to her. Krasbeth knew of Swenson's emotionally fragile condition stemming from her history as an alcoholic, and the resulting stress forced her to seek counseling. After leaving NCI, Swenson sued for intentional infliction of emotional distress; the trial court granted summary judgment for the defendants, finding no reasonable jury could deem the conduct sufficiently outrageous, and Swenson appealed.