California, United States of America
The following excerpt is from Logan v. Southern Cal. Rapid Transit Dist., 136 Cal.App.3d 116, 185 Cal.Rptr. 878 (Cal. App. 1982):
The modern rule for stating this cause of action requires an allegation of conduct exceeding that which is usually tolerated by a decent society and of a nature which is expected to cause, and does cause, mental distress. (Agarwal v. Johnson (1979) 25 Cal.3d 932, 946, 160 Cal.Rptr. 141, 603 P.2d 58.)
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