Barbara G. and her supervisor, Scott R., were on a business trip together when the latter allegedly entered Barbara's hotel room and berated her about her work.
When the woman later filed suit claiming assault, defamation, and intentional infliction of emotional distress, the Rockland County Supreme Court refused to dismiss the case. But, on appeal, the Appellate Division, Second Department, thought that Scott's words weren't enough to support the lady's suit, particularly in the absence of "some menacing gesture or act."
They gave her the business.
To view a copy of the Appellate Division's decision, please use this link: Barbara G. v. Scott R.