Human resources professionals have been breathing a bit easier because of the retrenchment in the "At-Will" Employment Doctrine.(1) The repreive was short lived, however, as a relatively new employee relations law scourge has surfaced- The Tort doctrine of .(2) Although this theory is not new, it's prominenece is growing. This added cause of action in tort law is resulting in increased employer liability and risk. Often, Court award outcomes in these cases are in the hundreds of thousands of dollars, and more, and are likely to be upheld ....