There is no cognizable claim for intentional infliction of physical distress under California law. See Free v. Peikar, No. 1:17-cv-00159 MSJ (PC), 2017 U.S. Dist. LEXIS 61985, at *17 (E.D. Cal. Apr. 24, 2017) (“Plaintiff has also asserted a claim for intentional infliction of physical distress. There is no such claim, however, under California law.”). Further, we are unaware of any such claim for relief under federal law.
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