Taylor v. Metzger
Supreme Court of New Jersey
706 A.2d 685 (1998)
Carrie Taylor (plaintiff), an African American sheriff's officer of 20 years, encountered Sheriff Henry Metzger (defendant) at a police academy, and when she greeted him he turned to another officer and used a racial slur to refer to her. Taylor became severely distressed, was later diagnosed with what was ultimately characterized as post-traumatic stress disorder, and testified to insomnia, nightmares, hair loss, and fear of being alone. Metzger twice attempted to apologize in writing, which Taylor refused to accept, and while her pay and basic job status were unaffected, she lost a supervisory position and was labeled a "troublemaker" by some coworkers. The trial court granted summary judgment for Metzger, and the appellate division affirmed; Taylor sought review from the state supreme court.
Whether a single utterance of a racial slur, made by a high-ranking public official to a subordinate, can constitute extreme and outrageous conduct supporting a claim for intentional infliction of emotional distress under New Jersey law.