father should not have visitation rights because of the emotional impact on the child. The father, meanwhile, had sued in federal district court claiming intentional infliction of emotional distress under Virginia law. He obtained a money judgment which was reviewed by the Fourth Circuit in Raftery. Because the appellate issues concerned the domestic relations exception to federal diversity jurisdiction and the Virginia law of alienation of affections, the Fourth Circuit simply noted that “[tjhere was evidence clearly sufficient to establish that the former wife had engaged in a continuing and successful effort to destroy and to prevent rehabilitation of the relationship between the former husband and their son.” Id. at 337. See also Sheltra v. Smith, 136 Vt. 472, 392 A.2d 431 (1978) (<HOLDING>); Bartunus v. Lis, 332 Pa.Super. 48, 480 A.2d
recognizing validity of cause of action for intentional infliction of emotional distress holding that a cause of action for the intentional infliction of emotional distress was stated by allegations that the defendant had rendered impossible any personal contact or other communication between the plaintiff and her daughter holding that act did not bar intentional infliction of emotional distress claim recognizing the tort of intentional infliction of emotional distress holding that intentional infliction of emotional distress is a personal injury tort