Jeannie Cook

Summary

The Wyoming Supreme Court affirmed summary judgment for Shoshone First Bank on claims arising from the suicide of teller Christina Proefrock hours after the bank accused her of stealing $1,200 in missing funds. The court held the claims were not barred by worker's compensation because Proefrock suffered no compensable physical injury and her willful suicide is excluded from coverage, but that no genuine issue of material fact existed on intentional infliction of emotional distress because the bank's investigation and questioning of suspects was not extreme and outrageous as a matter of law, and no wrongful act was shown to support liability for negligently caused suicide. The court declined to address the foreseeability-of-suicide question, holding it becomes relevant only if extreme and outrageous conduct is first shown.