By The Law Offices of John Day, P.C. on Jun 13, 2025 06:00 am
A woman who was left at a bus stop in the cold by a bus driver did not state a claim for intentional infliction of emotional distress. In Williams v. Holt, No. M2024-01188-COA-R3-CV (Tenn. Ct. App. May 1, 2025), the plaintiff was waiting at a bus stop on a November morning without a coat. When the next bus for that station pulled up, it initially pulled into a different bay because the correct bay was blocked. After seeing the plaintiff, the driver pulled to the correct bay, opened the doors, and said, “Come on, now.” The plaintiff asked the driver to lower to the steps for her, at which point the driver closed the doors and left plaintiff. The plaintiff expressed her concerns at the customer service desk, where a worker said she would file a complaint for the plaintiff. The plaintiff boarded the next bus twenty-six minutes after the previous bus left the plaintiff. The plaintiff later learned that the worker never filed a complaint. The plaintiff filed this case pro se, asserting a claim for intentional infliction of emotional distress (“IIED”) against the bus driver and customer service representative who failed to file a complaint. She also alleged negligent infliction of emotional distress (“NIED”) against the Metropolitan Transit Authority, who she alleged employed the driver and worker. The trial court granted summary judgment to the defendants on all claims, which was affirmed on appeal.
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