Although the employment relationship is a factor to be considered, Taylor v. Metzger, 152 N.J. 490, 511 (1998), the elements of proof on a claim of intentional infliction of emotional distress, in accordance with Buckley v. Trenton Saving Fund Society, 111 N.J. 355, 366 (1988), are not altered by the "power dynamics of the workplace." Plaintiff's evidence that defendant supervisor directed her to remove pictures and ballet slippers of her deceased teenage daughter from her cubicle at work, and that she not talk about her daughter to co-workers, did not rise to the level of extreme and outrageous conduct, "to be regarded as atrocious, and utterly intolerable in a civilized community." Also, plaintiff's evidence was not sufficient to prove that the employer acted intentionally or recklessly to cause her emotional distress. 8-25-11
