in a defamation suit). Others involved claims under federal statutes that do not require administrative exhaustion. See Thurman v. DaimlerChrysler, Inc., 397 F.3d 352, 357-58 (6th Cir.2004) (affirming district court’s dismissal based on six-month contractual limitations period where plaintiff asserted discrimination claims under state law and 42 U.S.C. § 1981, as well as various state tort claims); Taylor v. W. & S. Life Ins. Co., 966 F.2d 1188, 1193-94, 1206 (7th Cir.1992) (affirming district court’s dismissal of section 1981, breach of contract, and wrongful discharge claims on contractual limitations grounds and affirming the district court’s judgment in favor of the plaintiff on the merits of his Title VII claim); Badgett v. Fed. Express Corp., 378 F.Supp.2d 613, 626 (M.D.N.C.2005) (<HOLDING>). CMH specifically cites Badgett as a case that
holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute recognizing that claims against a state under  1981 are barred by the eleventh amendment holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any holding that placement of a contractual limitations period in a section entitled claims was reasonable holding that plaintiffs emotional distress  1981 and fmla claims are barred as untimely under a sixmonth contractual limitations period