Standard Fruit & Vegetable Co. v. Johnson
985 S.W.2d 62 (Tex. 1998)
A reckless truck driver crashes; the distress was a side effect, not the aim
- In one lineEn una línea
- IIED requires intent or recklessness as to severe emotional distress itself; distress that is only a side effect of conduct aimed at other harm does not qualify.El IIED exige intención o imprudencia respecto de la angustia emocional severa en sí; la angustia que es solo efecto colateral de una conducta dirigida a otro daño no basta.
- RuleRegla
- The first element of IIED is satisfied only when the defendant intended to cause severe emotional distress, knew it was substantially certain to result, or consciously disregarded a high probability of it; conduct whose primary risk is physical injury or some other harm, with distress as an incidental consequence, is not enough.
- Why this case is herePor qué está aquí este caso
- Defines the intent element: the defendant must intend or be reckless about causing severe emotional distress itself, not some other harm of which distress is a byproduct.
- Procedural posturePostura procesal
- Plaintiff recovered for IIED after a traffic collision caused by the defendant's driver; the Supreme Court of Texas held the evidence legally insufficient and rendered judgment that the plaintiff take nothing on that claim.
Facts
A Standard Fruit delivery driver drove recklessly and caused a collision. A person affected by the crash sued the company for intentional infliction of emotional distress based on the driver’s conduct and the distress of the incident.
Procedural posture
The plaintiff obtained a judgment on the IIED claim; the court of appeals affirmed. The Supreme Court of Texas held the evidence legally insufficient on the intent element and rendered a take-nothing judgment on that claim.
Issue
Whether reckless driving that causes an accident can satisfy the “intentional or reckless” element of IIED when the distress was not the object or primary risk of the conduct.
Holding
No. The driver’s conduct risked physical harm; any emotional distress was incidental, so the first element was not met.
Reasoning
The tort is intentional: the defendant must direct the conduct at causing severe emotional distress, know it is substantially certain to result, or consciously disregard a high probability of it. Reckless driving creates a risk of injury, not a design to distress, and allowing IIED on such facts would convert ordinary accident cases into intentional torts.
Rule (own words)
Intent and recklessness are measured against the distress itself. If the defendant was aiming at something else, element one fails.
What-ifs
- If the driver had deliberately swerved at the plaintiff to frighten him, element one would be met.
- The analysis pairs with element two: conduct that is intended to distress still has to be outrageous.
Likely follow-upsRepreguntas probables
What is the difference between recklessness here and ordinary negligence?
How does this help Luther Reynolds?
Must the conduct be directed at the plaintiff?
Say the answer out loud before revealing each part. Rate yourself honestly; the case comes back sooner when you miss.Di la respuesta en voz alta antes de revelar cada parte. Califícate con honestidad; el caso vuelve antes si fallas.
Panic kit: “Could you repeat the question, please?” · “Let me make sure I have the facts right: …” · “I'm not certain, but I'd argue … because …”Kit de pánico: “Could you repeat the question, please?” · “Let me make sure I have the facts right: …” · “I'm not certain, but I'd argue … because …”