Law.com has this article from the Miami Daily Business Review discussing the unsual case against Citigroup (previously noted here) alleging the Florida tort of "outrage," which appears to be a variation of intentional infliction of emotional distress. The case seeks to hold Citigroup liable for, among other things, the plaintiff's alleged pain and suffering from losing $2 million when WorldCom stock plummeted.

The article states that after being told that at least one prominent securities defense attorney found the claim laughable, plaintiff's attorney Ted Babbitt countered "We'll see who laughs last.... It only takes a finding by one judge to make this cause of action available to millions of shareholders."