Lackawanna steel company and Larry Sampsell appealed to the United States Court of Appeals against appellee Elijah Turley. Elijah Turley (plaintiff) was an African-American steelworker at the Lackawanna company who was racially targeted and harassed daily at the plant for three years. This included things such as verbal racial degrading, KKK references on his workstation, vandalism of his car, death threats, and even a toy monkey with a noose around its neck found on his car. His management and supervisors knew and even participated in said events, including defendant Larry Sampsell who was his manager. When Turley would tell management, usually nothing would be done. Sampsell even went as far as to not let police investigate the situation by denying them access to surveillance footage. Turley went on to suffer serious psychiatric problems. He sued Lackawanna and supervisors for intentional infliction of emotional distress. The defendants appealed as they thought it did not meet the requirements for this tort.

Is a clear lack of action against harassment alongside complicity a valid claim for intentional infliction of emotional distress? why?