What is the test for a cause of action for intentional infliction of emotional distress against Flores?

A cause of action for intentional infliction of emotional distress requires "'extreme and outrageous conduct'" by the defendants. (Davidson v. City of Westminster (1982) 32 Cal.3d 197, 209.) To be outrageous, conduct "must be so extreme as to exceed all bounds of that usually tolerated in a civilized community." (Ibid.) A court may determine as a matter of law whether the facts pled in a complaint meet that requirement. (Id. at p. 210.) Selective enforcement of city ordinances against Flores does not, as a

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