context: 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. Indeed, at least one court has held that even in the absence of excessive force, allegations that a police officer uses ethnic slurs against arrestees suffice to state an IIED claim.
citation_a.signal: but see
citation_a.identifier: 221 F.3d 883, 890
citation_a.parenthetical: holding that motorist's allegation that racial epithet was used against him, coupled with officers' justifiable use of force, did not state IIED claim
citation_a.sentence: But see Watkins v. City of Southfield, 221 F.3d 883, 890 (6th Cir.2000) (applying Michigan law) (holding that motorist’s allegation that racial epithet was used against him, coupled with officers’ justifiable use of force, did not state IIED claim).
citation_b.signal: see
citation_b.identifier: 598 N.W.2d 657, 660-61, 663
citation_b.parenthetical: upholding jury verdict on IIED claim in favor of arrestees where officers used justifiable force but also used racial epithet and disparaging names
citation_b.sentence: See Kelly v. City of Minneapolis, 598 N.W.2d 657, 660-61, 663 (Minn.1999) (upholding jury verdict on IIED claim in favor of arrestees where officers used justifiable force but also used racial epithet and disparaging names).