Question:
Azhar Ali Khan, an employee of Parsons Global Services, Ltd., was working for Parsons in the Phillipines. On one of his days off, when Parsons' offices were closed, Khan was kidnapped. He was later tortured. According to allegations made by Mr. Kahn and his wife, Asma Azhar Khan, in the complaint referred to below, Parsons delayed paying the ransom that was demanded until after Mr. Khan's kidnappers carried out their threat to cut off part of his ear. The Khans filed suit against Parsons in an effort to obtain damages for the physical and emotional harms they experienced as a result of the kidnapping incident and Parsons' response to it. In one portion of the complaint, Mrs. Khan brought an intentional infliction of emotional distress claim against Parsons. (In a portion of the complaint not being asked about here, Mr. Khan sought damages from Parsons on a negligence theory.) Ruling that Mrs. Khan had failed to state a lawful cause of action, the federal district court dismissed Mrs. Khan's claim. Mrs. Khan then appealed to the U.S. Court of Appeals for the D.C. Circuit. Were Mrs. Khan's allegations sufficient to give rise to a claim for intentional infliction of emotional distress?