Court of Appeals for the District of Columbia Circuit affirms the district court's findings in most respects, such as FSIA jurisdiction; affirms the default judgments; but certifies a question of state law to the District of Columbia Court of Appeals, namely "whether a plaintiff must be present at the scene of a terrorist bombing in order to recover for IIED
579, 580 (1993) (IIED
"substantive standards are ill defined, requiring the trier of fact in each case to render an ad hoc judgment about the outrageousness of the particular defendant's particular conduct.").
(International Institute of Environment and Development).
One problem that could emerge in trying to use IIED
in place of alienation of affection or criminal conversation is that a judge or jury may find "adultery does not evidence the extreme and outrageous conduct" required by IIED
Director Andrew Norton said the least-developed countries currently get less than a third of all international climate funding provided by wealthy governments.
(91) Recovery by the plaintiff requires that the defendant's act created an oppressive circumstance that goes beyond the "common and unavoidable situations in which a person faces extreme stress[,]" and the environment must be stressful enough to be "unbearable even for persons of ordinary fortitude." (92) IIED
cases often involve a power imbalance between the tortfeasor and victim-- an imbalance that the tortfeasor knowingly exploits (93)--and the Restatement specifically references the abuse of a position of authority as a factor that could constitute outrageous conduct.
A best-practice protocol for consultation had been developed by the UK-based think-tank, IIED
(International Institute for Environment and Development) with Norwegian funds (IIED
Adaptation strategies for health have been submitted by World Bank, UNFCCC and IIED
by improving infrastructure, evaluation studies, preventative measures and regulatory bodies.
Although the majority of the Court denied any IIED
infliction of emotional distress (IIED
) tort and the expanded protection