phenomenon of "workplace bullying" and the need for status-blind hostile work environment protection, The

189, See, e.g., Mandani, 818 P.2d at 934; Franco, 971 S.W.2d at 54; Farnum, 671 A.2d aE 1256.

190. Cf. McCain v: Eaton Corp., 623 N.YS.2d 626, 627 (N.Y. App. Div. 1995) (lIED "cannot be pleaded for the purpose of circumventing the rule prohibiting an at-will employee from suing for wrongful discharge".

191. See Clark v. Eagle Sys., Inc.. 927 P.2d 995, 1000 (Mont. 1996) (holding that where plaintiffs demotion "was attributable to unsatisfactory job performance" summary judgment on 11ED claim was proper); cf. Bozzuto v. Holler, No. 355625, 1996 WL 737516, at *3 (Conn. Super. Ct. Dec. 12, 1996) (where defendant issued three written warnings to plaintiff for poor job performance, summary judgment on IIED count denied only on question of whether the manner in which the discipline was executed constituted outrageous conduct).

192. Sebesta, 886 S.W.2d at 461 (plaintiff told of termination, immediately assisted in packing her belongings, then escorted out of the building to her car by the director of personnel and a warehouse employee "when everyone was returning from lunch"); Wornick Co. v. Casas, 856 S.W.2d 732, 733-34 (Tex. 1993) (plaintiff told of termination despite favorable job evaluations, ordered to leave premises immediately, escorted to her car with boxes of her belongings by two security guards).

193. See, e.g., Sebesta, 886 S.W.2d at 463 (holding that exit parade cannot "be reasonably regarded as extreme or outrageous"); Wornick, 856 S.W.2d at 736 (same); see also Muniz v. Kravis, No. CV-94-0065789, 1995 WL 542120, at *6 (Conn. Super Ct. Sept. 6, 1995) (finding no outrageous conduct when employer used an armed security guard to notify plaintiffs of their termination and gave them 24 hours to vacate the premises, where one plaintiff was on vacation and the other had just returned to work after surgery the day before). Note; however, that allegations of discriminatory animus may have a positive effect on IIED claims relating to the manner of discharge as well. See Hosaflook v. Consolidation Coal Co., No. 23045, 1996 WL 717106, at *8 (W. Va. Dec. 10, 1996) (reversing summary judgment for defendant in case involving alleged disability discrimination.

In a slightly older, seemingly anomalous case concerning the manner in which a person was fired, the Massachusetts Supreme Judicial Court upheld an lIED claim where a restaurant manager gathered his waitstaff together and promised to fire them in alphabetical order until someone produced the name of an alleged thief. See Agis v. Howard Johnson Co., 355 N.E.2d 315, 316 (Mass. 1976). Plaintiff Debra Agis was the first person fired, and the court found her allegations of outrageousness and severe emotional distress sufficient to reinstate her complaint. See id at 319, Since Agis, however, the court has held that workplace lIED claims are barred by the state's workers' compensation statute. See Green v. Wyman-Gordon Co., 664 N.E.2d 808, 813 (Mass. 1996) (holding that exclusivity provision of workers" compensation law bars common-law emotional distress claims).