Posting Video of 10-Year-Old Hockey Player's "Tantrum" Isn't Intentional Infliction of Emotional Distress
A 10-year-old hockey player and his parents sued an anonymous YouTube user for posting a video of the boy's emotional reaction after missing a penalty shot, alleging intentional infliction of emotional distress. The Illinois Appellate Court ruled that the video posting did not meet the legal threshold for extreme and outrageous conduct required for such a claim. The court reversed the lower court's decision to disclose the poster's identity, emphasizing the importance of free speech and the public nature of youth sports events.
- ▪The video, titled 'TI Tantrum,' showed the 10-year-old player screaming, throwing equipment, and falling to the ice after missing a crucial shot.
- ▪The plaintiff alleged ongoing emotional harm and social ostracism, while his parents claimed psychological distress and marital strain.
- ▪The court found the poster's conduct did not rise to the level of extreme and outrageous behavior necessary for intentional infliction of emotional distress.
- ▪The plaintiff was a known youth athlete in high-profile, publicly streamed tournaments, indicating familiarity with public scrutiny.
- ▪The court dismissed claims of defamation and right of publicity with prejudice and reversed the order to disclose the anonymous poster's identity.
Opening excerpt (first ~120 words) tap to expand
Free Speech Posting Video of 10-Year-Old Hockey Player's "Tantrum" Isn't Intentional Infliction of Emotional Distress Eugene Volokh | 5.4.2026 8:01 AM In Mufarreh v. Google, Inc., decided Friday by the Illinois Appellate Court (Justice Raymond Mitchell, joined by Justices Sharon Oden-Johnson and Thaddeus Wilson), a 10-year-old hockey player and his parents sued an anonymous video poster, and sought to discover the poster's name: [I]n a competitive youth hockey game[,] Mufarreh missed the final penalty shot, losing the game, and had a severe emotional response on the ice. Among other things, he screamed, threw his hockey stick, gloves, and helmet, and fell to the ground. On November 2, 2023, YouTube user FunnyIllinoisHockey uploaded a compilation video of Mufarreh's emotional episode.
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Excerpt limited to ~120 words for fair-use compliance. The full article is at Reason.com.
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