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Nagata v. Quest Diagnostics Inc.

United States District Court for the District of Hawai’i
303 F. Supp. 2d 1121 (2004)


Facts

On January 19, 1999, Nagata (plaintiff) took a urine test as requested by his employer, Garden Isle Telecommunications. Quest Diagnostics Inc. (defendant) tested the urine sample and found that it was inconsistent with human urine. Garden Isle fired Nagata as a result of the test. Thereafter, Nagata suffered from depression and substance abuse, and contemplated suicide. On January 10, 2001, Quest informed Garden Isle that it had used incorrect testing procedures between January 4, 1999, and February 2, 1999. Quest discovered the mistake in February 1999. The improper procedures could have resulted in erroneous results to Nagata’s test. On January 25, 2001, Garden Isle notified Nagata of Quest’s error and offered Nagata his job back. Nagata brought suit against Quest for intentional infliction of emotional distress based on the company’s intentional withholding of the testing error from Garden Isle and Nagata for almost two years. Quest filed a motion for summary judgment.

Rule of Law

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Issue

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Holding and Reasoning

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