or outrageous to state a claim for intentional infliction of emotional distress. However, in light of the evidence discussed above that Sergeant McNicholas had conspired to manufacture the evidence on which such a conviction would be based— viz., the Mejias’ possession of the cocaine, his actions do begin to take on an extreme and outrageous character. Second, Sergeant McNicholas’s alleged repeated use of ethnic slurs against them during the course of the Mejias’ arrest and subsequent interrogation would probably be sufficient on its own to state a claim for IIED. Several courts have held that a police officer’s use of ethnic slurs, when coupled with use of excessive force, is sufficient to state an IIED claim. See, e.g., Holder v. Ivanjack, 39 F.Supp.2d at 970 (applying Illinois law) (<HOLDING>); Oliver v. Cuttler, 968 F.Supp. 83, 93
holding that plaintiff stated iied claim where officer allegedly hurled racial epithets at him and struck him without provocation holding that because plaintiffs iied claim is based on the facts that support plaintiffs malicious prosecution claim plaintiffs iied claim did not accrue until the charges against them were dismissed holding that plaintiff stated iied claim where officers yelled racial slurs at attacked and filed false charges against him holding that the use of racial slurs and menacing remarks constitute severe conduct holding that motorists allegation that racial epithet was used against him coupled with officers justifiable use of force did not state iied claim