The intentional infliction of emotional distress is a new tort and punishes a wide range of conduct, including the publication or broadcast of material that is outrageous and causes severe emotional distress. Courts have made it extremely difficult for plaintiffs to win such suits by placing a substantial burden of proof on the injured party. The Supreme Court added to this burden in 1988 when it ruled that public-person plaintiffs would have to show actual malice as well to win their lawsuits. What case in recent years is related to this tort? was it the right decision?