actually or proximately caused by the outrageous conduct.” Fromson v. State, 2004 VT 29, ¶ 14, 176 Vt. 395, 848 A.2d 344 (quotation omitted). This is a heavy burden that requires plaintiff to show that the City’s conduct “was so outrageous in character and so extreme in degree as to go beyond all possible bounds of decent and tolerable conduct in a civilized community and be regarded as atrocious and utterly intolerable.” Id. (quotation omitted). The standard for outrageousness is objective. Id. ¶ 15. Therefore, an employer’s conduct must be assessed with an objective standard based on the employer’s actions and words, not on what the employee personally believed motivated the employer’s conduct. See Baldwin v. Upper Valley Servs., Inc., 162 Vt. 51, 57, 644 A.2d 316, 319 (1994) (<HOLDING>). ¶29. Plaintiff’s complaint and motion for
holding that defendants alleged defamatory statements that plaintiff made loans in exchange for sexual favors did not constitute outrageous conduct holding that it was not error for trial court to decline to conduct full evidentiary hearing before trial on outrageous government conduct claim holding that arrest made with probable cause and without excessive force does not give rise to iied claim holding that standard for iied is objective and there was no outrageous conduct where plaintiff simply made vague assertions about employers motives for his dismissal holding that even assuming defendant intentionally mishandled mortgagerelated documents such conduct is notthe type of beyondthepale outrageous conduct that may be covered by an iied claim