Watts v. Chittenden, 301 Conn. 575

Watts and Chittenden were married in 1993; dissolution filed in 1999 with joint custody arrangements.
Chittenden made repeated false allegations of Watts's sexual abuse of their daughters beginning May 1999.
Investigations ensued; Watts suffered distress as public and professional consequences followed.
Chittenden pleaded guilty in 2002 to false reporting and related charges; she admitted making false allegations.
Watts filed suit for intentional infliction of emotional distress on August 29, 2005; trial court ruled in Watts's favor, tolling with continuing conduct.
Appellate Court reversed, holding no duty existed to support the continuing course of conduct doctrine in an IIED claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must an original duty exist to apply the doctrine?	Watts contends no original duty is required for IIED.	Chittenden argues original duty is a precondition to tolling via continuing conduct.	Original duty not required; doctrine tolls IIED without duty.
Did the conduct constitute a continuing course of conduct tolling the statute?	Watts argues ongoing false allegations and investigations toll the period.	Chittenden argues gaps or lack of duty prevent tolling.	Yes; continued conduct from 1999 to 2002 and later tolls under § 52-577.

Appleton v. Board of Education, 254 Conn. 205 (2000) (elements of IIED; no duty requirement for liability)
Fichera v. Mine Hill Corp., 207 Conn. 204 (1988) (continuing duty requirement in negligence context)
Blanchette v. Barrett, 229 Conn. 256 (1994) (continuing duty and expert testimony where applicable)
Feltmeier v. Feltmeier, 207 Ill. 2d 263 (2003) (continuing tort approach to IIED; last act accrual)
Curtis v. Firth, 123 Idaho 598 (1993) (abusive relationship context and accrual after last act)
Smulewicz-Zucker v. Zucker, 98 Conn. App. 419 (2006) (disagreed on original duty prerequisite in IIED continuing doctrine)