Mary Ann Duke v. Jarlath M.H. Ffrench-Mullen (2)

Torts: Interference with parental rights and IIED: Sufficiency of pleadings

CSA No. 1806, Sept. Term 2012. Unreported. Opinion by Wright, J. Filed Oct. 10, 2013. Appeal from Montgomery County. Affirmed.

Dismissal of the mother’s complaint was proper, where her cause of action for interference with parental rights did not allege that she was denied visitation or that the father’s relocation was accomplished to intentionally circumvent the legal process or otherwise frustrate her access to their child, and the father’s alleged actions failed to rise to the level of extreme and outrageous conduct required to show intentional infliction of emotional distress.

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