Emotional distress. evidence, employer liability, private right of action.

Officials at Suburban National Bank appeal a lower court's ruling in a suit involving a former employee. Bank officials asked several employees to submit to a polygraph test after a client's deposits were discovered missing. Wanda Kamrath, a bank employee, submitted to the polygraph test. Afterward, Kamrath reported experiencing nightmares about the test and emotional distress over the incident. Kamrath sought treatment from a psychiatrist. The psychiatrist determined that Kamrath believed the bank's request that she submit to the polygraph test amounted to an accusation of improper conduct. Kamrath filed suit, seeking compensation for emotional disability.

A trial court jury ruled for Kamrath. The jury awarded damages and attorney fees. The bank now appeals, claiming the trail court gave inaccurate instructions to the jury.

Kamrath wins. The Minnesota Court of Appeals affirmed the lower court's ruling. The appeals court ruled the lower jurisdiction committed no reversible error in its handling of the case.