What is the test for intentional infliction of emotional distress?

The majority acknowledges the rigorous standards for a claim of intentional infliction of emotional distress. The qualifying conduct must be "so ' " 'extreme as to exceed all bounds of that usually tolerated in a civilized community.' " ' [Citation.] And [the] conduct must be ' " 'intended to inflict injury or engaged in with the realization that injury will result.' " ' " (Hughes v. Pair (2009) 46 Cal.4th 1035, 1050-1051.) Importantly, "[l]iability for intentional infliction of emotional distress ' "does not extend to mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities." (Rest.2d Torts, 46, com. d.)' " (Id. at p. 1051.) The Restatement of Torts explains that "plaintiffs must necessarily be expected and required to be hardened to . . . occasional acts that are definitely inconsiderate and unkind. There is no occasion for the law to intervene in every case where some one's feelings are hurt." (Rest.2d Torts, 46, com.

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