lack Letter
LRWSupreme Court of Texas, 1998draftborradorunverifiedsin verificar

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?
Recklessness means the defendant knew of a high degree of risk of severe emotional distress and acted anyway; negligence about a car accident is not recklessness about distress.
How does this help Luther Reynolds?
He will argue his comments aimed at Marcus's reputation or standing on the team, with distress as a side effect; Marcus must show Luther knew of the anxiety and the high risk of severe distress.
Must the conduct be directed at the plaintiff?
The court emphasized that the distress must be the intended or primary consequence as to that plaintiff, which is why bystander-type recoveries are limited.

AssignedAsignado: 2026-10-09, 2026-10-12, 2026-10-26, 2026-11-02

Read the public opinionLeer la opinión (texto público). SourceFuente: Own brief from the public opinion; IIED memo (LRW). Check the facts against the opinion before citing..