Case No. Rutherford Circuit No. 31613; Appeal No. 01A01-9709-CV-00531Regular Panel DecisionDec 02, 1998 Allen E. Hasty, Judy Darlene Hasty v. Thomas R. Throneberry, Ind., D/B/A Throneberry Properties and Sharon Clutter
Plaintiffs Allen E. Hasty and Judy Darlene Hasty sued Thomas R. Throneberry for wrongful eviction, outrageous conduct, and defamation. Hasty, a maintenance worker for Throneberry, was fired and subsequently evicted from an apartment provided as part of his compensation. Throneberry terminated electricity and changed locks, forcing Hasty out. Hasty claimed these actions, combined with a prior work-related car accident, caused Post-Traumatic Stress Disorder (PTSD) and major depression, for which he had already received worker's compensation benefits. The trial court dismissed defamation and outrageous conduct claims but allowed the wrongful eviction claim and later permitted amendment to include intentional infliction of emotional distress. A jury awarded Hasty $500 for property loss and $10,000 for mental damages, attributing 55% of the latter to Throneberry's actions, resulting in a total judgment of $6,000. Throneberry appealed, arguing the relationship was employer-employee, not landlord-tenant, precluding wrongful eviction, and that PTSD recovery was barred by worker's compensation exclusivity and lack of medical certainty. The Court of Appeals affirmed, holding that even if it was an employer-employee relationship, Throneberry had a duty to refrain from intentional, willful, or wanton conduct causing injury or loss, which Hasty's complaint alleged and the jury found. The court also ruled that worker's compensation exclusivity does not apply if the defendant intended to cause injury, which was alleged. Finally, Dr. Singh's testimony was found sufficient regarding causation, and apportionment of damages was a jury matter.
Wrongful EvictionIntentional Infliction of Emotional DistressEmployer-Employee RelationshipLandlord-Tenant DisputeWorkers' Compensation ExclusivityProximate CausationMedical Expert TestimonyPost-Traumatic Stress DisorderMajor DepressionComparative Fault