Nagata v. Quest Diagnostics

United States District Court for the District of Hawaii · Torts

TortsIntentional Infliction of Emotional DistressSummary JudgmentIIEDintentional or recklessoutrageous conductcausationextreme emotional distress

Facts

Plaintiff provided a urine sample to his employer under a drug-testing policy, and defendant laboratory reported that the sample was inconsistent with human urine, after which the employer terminated plaintiff. Defendant later informed the medical review officer in January 2001 that during the relevant period it had not measured creatinine concentration to at least one decimal place and therefore did not know whether plaintiff's sample actually met the criteria for a substituted specimen. Defendant canceled the test and instructed that any personnel action based on the canceled test no longer had a basis in DOT regulations. Plaintiff was then notified by mail and offered his job back, and his remaining claim alleged intentional infliction of emotional distress based on defendant's delay in disclosing this information.

Issue

Whether defendant was entitled to summary judgment on plaintiff's IIED claim where the claim was based not on the original testing error, but on defendant's alleged delay in disclosing that the test result could not be validated. More specifically, the question was whether the record showed no genuine issue of material fact on the elements of intentional or reckless conduct, outrageousness, causation, or extreme emotional distress.

Rule

Under Hawaii law, an IIED claim requires proof that: (1) the conduct allegedly causing the harm was intentional or reckless, (2) the conduct was outrageous, (3) the conduct caused the plaintiff's distress, and (4) the plaintiff suffered extreme emotional distress. The court clarified that recklessness in this context means the defendant must know, or have reason to know, the facts creating the risk, and that severe emotional distress includes mental suffering and highly unpleasant mental reactions without requiring likelihood of illness.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Portland, Oregon, Pine Harbor Screening Lab processed an employee drug screen for Mateo Ruiz. The lab discovered in March 2022 that, during the relevant testing period, it had not been using a required reporting method and that the result on Mateo's sample could not be validated, but it did not notify the employer's review physician until March 2023, even though it knew employers relied on such results in making termination decisions.

Mateo sues the lab for intentional infliction of emotional distress based solely on the one-year delay in disclosure, alleging prolonged unemployment and severe depression. On the lab's motion for summary judgment, which is the strongest basis for denying the motion on the first element of IIED under Hawaii law as described in the opinion?

Explanation. The majority states that IIED in Hawaii requires intentional or reckless conduct, and defines recklessness as knowing or having reason to know the facts creating the risk. The court reasoned that even without knowing the plaintiff's identity, a defendant could foresee that the person tied to the sample could be harmed by delayed disclosure. Thus summary judgment should be denied if a jury could find the lab knew or had reason to know its delay posed a high degree of risk of serious harm. (Derived from Nagata v. Quest Diagnostics (n.d.).)