California, United States of America
The following excerpt is from Gonzalez v. 15115-15125 Victory Blvd., LLC, B231680 (Cal. App. 2012):
with an intent which is tortious or even criminal, or that he has intended to inflict emotional distress, or even that his conduct has been characterized by 'malice,' or a degree of aggravation which would entitle the plaintiff to punitive damages for another tort. Liability has been found only where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community." ' [Citation.]" (McMahon v. Craig (2009) 176 Cal.App.4th 1502, 1517 (McMahon).)
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