In Campbell v. Columbia Univ., decided Friday by Judge Vernon S. Broderick (S.D.N.Y.), Campbell, who had been admitted to Columbia's Negotiation and Conflict Resolution program, sued Columbia for intentional infliction of emotional distress, based on Columbia's denying her an "Impact HBCU Fellowship." "After being denied the fellowship, Campbell reported depression and hormonal imbalances that ultimately led to a trip to the emergency room." Campbell also ended up alleging "a far-reaching conspiracy involving collusion between Columbia and numerous figures, including high-level officials in the state government of Pennsylvania. The essence of these claims is that Columbia bribed the governor of Pennsylvania and a range of other officials to target Campbell and interfere with this lawsuit."
The court granted Columbia's motion to dismiss:
Taking this record together and construing it liberally [because plaintiff is representing herself] reveals two causes of action. The first cause of action is the intentional infliction of emotional distress claim, based on Columbia's failure to award Campbell a scholarship through the Impact HBCU Fellowship, or any other grant or work study-based support to allow her to attend Columbia. Campbell alleges that this occurred because "Columbia University wanted [her] to die." She further alleges that she "suffered from continual blood loss, anemia, anxiety, depression, shakes, shills, vomiting, body aches, nightmares, [and] hot flashes, due to her trauma of not being selected for the fellowship, being denied financial aid, and being ignored by [Columbia personnel]."
Taking all of these as true for the purposes of Columbia's motion to dismiss, Campbell does not plead a claim for intentional infliction of emotional distress. The four elements of a claim of intentional infliction of emotional distress are "(1) extreme and outrageous conduct, (2) intent to cause severe emotional distress, (3) a causal connection between the conduct and the injury, and (4) severe emotional distress." Columbia challenges only the first two elements (extreme and outrageous conduct and intent to cause the same), and so does not suggest, taking Campbell's allegations as true, that she has failed to allege causation or severe emotional distress.
