because of his termination, employment is no longer “at will.” Thus, limiting the tort of negligent infliction of emotional distress to termination cases does not go far enough. Moreover, requiring something more than mere termination of employment gives the employer little protection. There are usually events leading up to the termination sufficient to send the matter to the jury. Thus, to the extent an independent tort of negligent infliction of emotional distress is recognized in employment terminations, it is imperative that it be narrowly circumscribed to cases of severe emotional distress resulting from egregious conduct by the employer. Otherwise, this tort will eviscerate the concept of at-will employment. See Collins v. Gulf Oil Corp., 605 F.Supp. 1519, 1523 (D.Conn.1985) (<HOLDING>); Roberts v. Andersen Laboratories, Inc., No.
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 holding that under south dakota law compensation for negligent infliction of emotional distress requires manifestation of physical symptoms and intentional infliction of emotional distress requires an extreme disabling emotional response recognizing validity of cause of action for intentional infliction of emotional distress holding that the law does not recognize a cause of action for negligent infliction of emotional distress every time an employer negligently fails to comply with performance evaluation procedures resulting in an employees termination and emotional distress recognizing torts of intentional and negligent infliction of emotional distress