Over the years, the Wisconsin Supreme Court has been fairly liberal in providing remedies for emotional distress which results from intentional torts. However, such redress has not always been extended in a steady and even fashion, nor has its evolution always proceeded in a manner consistent with society's growing sensibilities regarding emotional distress. A survey of the Wisconsin law is appropriate both to provide a synthesis of the various strands in the area of emotional distress recovery, and in order to reflect on the problems with respect to such recovery. Before proceeding to specific considerations, however, it may be helpful to become acquainted with the opposition to the extension of recovery for emotional distress.
