Yates v. John Marshall Law School

Yates (plaintiff), who suffered from depression, anxiety, and homelessness, applied twice to John Marshall Law School (defendant) and was denied both times. After the second denial, she met with the dean, disclosed her mental illness and homelessness, and he agreed to reconsider — but ultimately denied her again, citing her LSAT score. She met with him once more, and he later declined further meetings with her. Yates sued for intentional and negligent infliction of emotional distress, and the school moved to dismiss.

Whether the tort of intentional infliction of emotional distress requires that the defendant's conduct be extreme and outrageous.