Wilson v. Univ. of Ala. Health Servs. Found., P.C., 266 So. 3d 674

Plaintiff Lisa Wilson sued University of Alabama Health Services Foundation (UAHSF) and four treating physicians, alleging repeated, tactless, and egregious statements to her and her terminally ill mother while the mother was hospitalized for recurrent colon cancer.
Elizabeth Wilson had an advance health-care directive instructing caregivers to use all available means to preserve life and named Lisa as her health-care proxy.
Complaint pleaded a single cause of action labeled as the tort of outrage (intentional infliction of emotional distress) and sought compensatory and punitive damages; UAHSF was sued vicariously for its doctors.
Defendants moved to dismiss under Rule 12(b)(6), arguing Alabama law limits the tort of outrage to narrow, historically recognized contexts and that the complaint did not state a viable claim as a matter of law.
The trial court dismissed, citing precedent that the tort is confined to three recognized categories and leaving it to the Supreme Court to decide whether to expand the tort.
The Supreme Court reversed and remanded, holding the trial court mischaracterized the law and directing the trial court to apply the Rule 12(b)(6) standard to determine whether the factual allegations, accepted as true, state a claim that is "so extreme in degree as to go beyond all possible bounds of decency."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wilson's allegations state a cognizable tort-of-outrage (IIED) claim	Wilson argued the alleged conduct was extreme, intentional/reckless, and caused severe emotional distress sufficient to state outrage/IIED	Defendants argued Alabama law confines outrage to narrow categories and the healthcare-context allegations cannot sustain the tort; thus dismissal under Rule 12(b)(6) was proper	Reversed and remanded: the court held the tort is not strictly limited to three categories; the trial court must, under Rule 12(b)(6), accept the allegations as true and decide whether they meet the extreme-outrage standard
Whether the trial court correctly stated the law limiting the tort to three circumstances	Wilson contended the tort can exist outside those three contexts and cited precedents recognizing other extreme facts	Defendants relied on prior decisions rejecting expansion of outrage claims in medical contexts	Court held the trial court erred to the extent it said the tort is limited to only those three categories and noted prior cases where outrage was recognized outside them; remanded for application of dismissal standard

Green Tree Acceptance, Inc. v. Standridge, 565 So.2d 38 (Ala. 1990) (elements of the tort of outrage/IIED and extreme-outrage standard)
Potts v. Hayes, 771 So.2d 462 (Ala. 2000) (discussion of historically recognized contexts for the tort of outrage)
Little v. Robinson, 72 So.3d 1168 (Ala. 2011) (recognition that outrage can be viable outside the three classical categories)
Callens v. Jefferson Cty. Nursing Home, 769 So.2d 273 (Ala. 2000) (healthcare-context limitations discussed by defendants)
O'Rear v. B.H., 69 So.3d 106 (Ala. 2011) (example of outrage recognized in a nontraditional factual context)
American Rd. Serv. Co. v. Inmon, 394 So.2d 361 (Ala. 1980) (formulation emphasizing outrage must go beyond insults, annoyances, or petty oppressions)