Elijah Turley was a steelworker at the Lackawanna company’s plant near buffalo, New York. For over a decade, he was the only African-American in his department. For the last three years of his employment, Lackawanna employees tormented and degraded Turley while his supervisors watched, condoned, and even participated.

On a daily basis, Turley’s coworkers subjected him to racist epithets and degrading treatment. They referred to him as “boy.” One witness estimated that 30 percent of the workers referred to him as “that f****** n*****.” Coworkers broadcast monkey sounds over the plant’s intercom system. On several occasions, Turley arrived at work to find the initials “KKK” – in reference to the Ku Klux Klan - spray-painted on his workstation. Others vandalized Turley’s car.

There were also death threats. Lackawanna employees terrorized Turley anonymously over the intercom, yelling “We[‘re] going to f****** kill you, f****** n*****, we’re going to kill your f****** Jewish lawyer too.” In one incident, a coworker told Turley to check on his car. Turley found, dangling from his side-view mirror, a stuffed toy monkey with a noose around its neck. Another staff member promised Turley that if he ever saw him “on the outside,” he would shoot him.

Lackawanna managers knew about the abuse, especially Larry Sampsell, head of security. Management was mostly unresponsive – but sometimes complicit. When a coworker viciously accused Turley in a meeting, Sampsell just stood by. When Turley reported death threats, Sampsell laughed. In all the years of harassment, the company only disciplined Turley’s tormenters twice. Sampsell also denied local police investigators access to company surveillance video. Rather than address Turley’s complaints, Sampsell set up a hidden camera that secretly recorded Turley while he worked.

The persecution left Turley a broken man, suffering serious psychiatric problems. Turley sued Lackawanna and his supervisors for intentional infl8iction of emotional distress (“IIED”) among other claims. Finding Lackawanna and Sampsell liable, a jury awarded Turley $1.3 million in compensatory damages (including $260,000 for IIED) and $5 million in punitive damages, plus attorney’s fees and costs.

Lackawanna and Sampsell appealed, arguing that the company and the supervisor’s inaction did not meet the standard for IIED. 

Questions:

1. Did Turley make a valid claim for intentional infliction of emotional distress?

2. What was the conduct that led to Turley’s claim of intentional infliction of emotional distress?

3. What was the defense of Sampsell and Lackawanna?

4. Did the court agree?