"Damages for mental and emotional distress are generally available merely upon proof of an intentional tort such as assault." Brower v Ackerly, 88 Wsh.App. at 92. Also, "...the law's recognition of infliction of emotional distress as an independent basis for tort liability is relatively new..." Id, at 96. And, "It is only within recent years that the rule stated in this Section has been fully recognized as a seperate and distinct basis for tort liability, without the presence of the elements necessary to any other tort, such as assault, battery, false imprsionment, trespass to land, or the like" Id, at 97.

What do you think?

EDIT: From the above case, it seems that intentional infliction of emotional distress is the same as the tort of "outrage."