California, United States of America
The following excerpt is from Prado v. Police Dep't of E. Palo Alto, A151297 (Cal. App. 2018):
The fifth cause of action alleges the intentional infliction of emotional distress. A claim here requires proof of "extreme and outrageous conduct by the defendant with the intention of causing, or reckless disregard of the probability of causing, emotional distress." (Cochran v. Cochran (1998) 65 Cal.App.4th 488, 494.) The police officer did not know the dog was in the yard when he entered it and certainly had no basis to believe
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