North Dakota Supreme Court

McMahon v. Sanford

November 5, 20252025 ND 184

Summary

The court affirmed dismissal of the plaintiff's six intentional infliction of emotional distress claims on summary judgment. It held that the denial of a continuance was not an abuse of discretion, the request for additional discovery was unpreserved, and claims based on medication decisions and discharge required an expert affidavit because those decisions involved medical expertise. The remaining claims failed because the alleged verbal abuse, humiliation, failure to investigate, and hostile conduct did not satisfy the extreme-and-outrageous standard as a matter of law.