What is the current state of the law on intentional infliction of emotional distress?

Almost all the cases involving public figures suing for intentional infliction of emotional distress involve publications, and are thus typically governed by the principles set forth in Hustler Magazine v. Falwell (1988) 485 U.S. 46. The rule is: A public figure "may not recover for the tort of intentional infliction of emotional distress . . . without showing . . . that the publication contains a false statement of fact . . . ." (Id. at p. 56.)