kidnapping; rather involved a police officer); Bedard v. Notre Dame Hosp., 151 A.2d at 690 (RI) (did not involve parental kidnapping; rather a hospital’s refusal to discharge infant); Armstrong v. McDonald, 39 Ala.App. 485, 103 So.2d 818 (1958) (third parties induced child to leave mother; no relatives involved). The remainder of the cases were federal court cases, which attempt to predict how the state supreme court will rule. Three jurisdictions have either deferred consideration or declined to create the tort. See McDougald v. Jenson, 596 F.Supp. 680 (N.D.Fla.1984), aff’d, 786 F.2d 1465 (11th Cir.1986); Bartanus v. Lis, 332 Pa.Super. 48, 480 A.2d 1178 (1984); Schuppin v. Unification Church, 435 F.Supp. 603 (D.Vt.1977); but cf. Sheltra v. Smith, 136 Vt. 472, 392 A.2d 431 (1978) (<HOLDING>). Also, in Illinois, the state court of appeals
recognizing the tort of intentional infliction of emotional distress holding parental child abduction compensable under intentional infliction of emotional distress holding that intentional infliction of emotional distress is a personal injury tort holding that act did not bar intentional infliction of emotional distress claim recognizing validity of cause of action for intentional infliction of emotional distress