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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Stephens v. Gilmour (2025)

Citation
Stephens v. Gilmour (2025)
Parent Document
Stephens v. Gilmour (2025)
Jurisdiction
Vermont (state)
Effective Date
2025-02-28

Other Sections in This Document (168)

Full Text

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The adjectives “extreme” and “outrageous” are used together in a fashion
        that might suggest that each merely emphasizes the other, rather than
        serving a distinct role. However, some conduct that may be outrageous—for
        example, marital infidelity—is sufficiently common that it could not be
        characterized as extreme (although today it may also not be outrageous).
        Similarly, some extreme conduct—climbing Mt. Everest, for example—is not
        outrageous. Thus, this double limitation, “extreme and outrageous,”
        requires both that the character of the conduct be outrageous and that the
        conduct be sufficiently unusual to be extreme.