Hollomon v. Keadle

Mary Hollomon (plaintiff) was employed by Dr. W. R. Keadle (defendant) for a little over two years. Hollomon left voluntarily, claiming she resigned because of Keadle’s cursing. On her second day, Hollomon understood Keadle to be a grouch who constantly cursed and yelled. Over the course of Hollomon’s employment, Keadle repeatedly cursed at and insulted Hollomon. According to Hollomon, she remained with Keadle’s office because she was a poor, single parent. Hollomon alleged that Keadle routinely made degrading remarks about women and aimed profanity at Hollomon in front of patients and coworkers. Hollomon also alleged that Keadle made veiled threats of physical harm. Hollomon claimed that Keadle’s conduct caused her a host of health problems, both physical and mental, including stomach pain and anxiety attacks. She reported her issues with Keadle to a counselor but did not seek counseling services. Keadle and another doctor gave Hollomon medication for her stomach problems, but there was no indication that Keadle knew the stomach problems were related to his use of profanity. Hollomon filed an action for the tort of outrage (also known as intentional infliction of emotional distress) in the trial court. The trial court dismissed Hollomon’s claim because the allegations were insufficient to support a claim for the tort of outrage. Hollomon appealed to the Arkansas Supreme Court.