California, United States of America
The following excerpt is from Glaser v. Meserve, B240385 (Cal. App. 2013):
Appellant next contends there was insufficient evidence to show that her actions caused substantial emotional distress, either objectively or subjectively. "[E]motional distress" is generally understood to include, among other emotions, fright, nervousness, anxiety, humiliation and worry. (See Thing v. La Chusa (1989) 48 Cal.3d 644, 648-649.) "Section 527.6 does not define the phrase 'substantial emotional distress.' However, in the analogous context of the tort of intentional infliction of emotional distress, the similar phrase 'severe emotional distress' means highly unpleasant mental suffering or anguish 'from socially unacceptable conduct' [citation], which entails such intense, enduring and nontrivial emotional distress that 'no reasonable [person] in a civilized society should be expected to endure it.' [Citations.]" (Schild v. Rubin, supra, 232 Cal.App.3d at pp. 762-763.)
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