In Lawler v. Montblanc North America, where Lawler, a store manager, was fired after telling her employer that she could not work more than 20 hours a week due to a medical condition, she sued for emotional distress and the appeals court held that:

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The court held that Lawler did not have a claim for emotional distress because the employer's conduct was not "outrageous" enough to meet the legal standard for such a claim.

In Lawler V