Newark, N.J. — A federal judge dismissed a New Jersey man’s emotional distress lawsuit against Atlantic Health Systems after he claimed an employee mocked his speech impediment during a phone call tied to a traumatic brain injury-related stutter.
U.S. District Judge Susan D. Wigenton issued the ruling Thursday in Newark federal court, addressing claims filed by plaintiff Paul Cuff against Atlantic Health Systems, Inc. The lawsuit centered on a March 16, 2025 phone conversation in which Cuff alleged an unnamed employee ridiculed his speech in front of other workers while knowing he had a medically connected speech defect.
Cuff argued the incident caused lasting psychological harm, emotional suffering, and ongoing medical treatment needs. The court reviewed the allegations as part of Atlantic Health’s motion to dismiss the complaint under federal civil procedure rules.
Lawsuit Claimed Emotional and Psychological Harm
According to court filings, Cuff alleged he was speaking with an unidentified Atlantic Health employee referred to in the complaint as “Robin Roe 1” when he overheard the employee mocking his stutter.
The complaint stated the employee knew Cuff “possessed a speech defect that caused him to stutter.” Court records said the stutter stemmed from a traumatic brain injury.
Cuff alleged the incident left him with “severe and painful psychological injuries” that required medical treatment. He further claimed the alleged conduct “incapacitated him from enjoying his life” and caused “permanent disabilities” requiring ongoing care.
The lawsuit asserted four claims tied to emotional distress. Two counts alleged intentional infliction of emotional distress against both the unnamed employee and Atlantic Health Systems. Two additional counts alleged negligent infliction of emotional distress.
Atlantic Health moved to dismiss the lawsuit in October 2025 after Cuff filed an amended version of his complaint.
Key Points
• Federal judge reviewed claims tied to an alleged March 2025 phone call mocking a speech impediment
• Plaintiff said his stutter resulted from a traumatic brain injury and caused lasting emotional harm
• Atlantic Health sought dismissal under federal court procedural rules
Judge Reviewed Multiple Versions of Complaint
The opinion outlined a lengthy procedural history before reaching the dismissal request.
Cuff initially filed his complaint on May 30, 2025. He later attempted to amend the filing in September 2025, but the court struck that version for failing to comply with federal procedural requirements under Rule 15(a)(1).
The judge later granted Cuff permission to submit a Second Amended Complaint, which became the operative filing reviewed in the latest ruling.
Atlantic Health then filed its motion to dismiss on Oct. 16, 2025, arguing the complaint failed to state claims upon which relief could be granted under Rule 12(b)(6).
Judge Wigenton’s opinion explained that courts reviewing dismissal motions must accept factual allegations in a complaint as true and determine whether a plaintiff could be entitled to relief under any reasonable reading of the claims.
The ruling cited Third Circuit precedent, including Mayer v. Belichick and Fowler v. UPMC Shadyside, which guide federal courts in separating factual allegations from legal conclusions during dismissal reviews.
Court Clarified Nature of Claims
Although portions of the complaint labeled some counts as negligence claims, the court determined the allegations were more accurately framed as negligent infliction of emotional distress claims.
The opinion noted that Cuff effectively conceded that point in briefing opposing Atlantic Health’s dismissal motion.
Court filings showed the claims focused almost entirely on emotional and psychological injuries allegedly tied to the single phone interaction.
The decision also emphasized that the alleged conduct involved unnamed employees identified only through placeholder names in the lawsuit.
No criminal allegations were involved in the case, and the court documents reviewed by the judge focused solely on whether the civil complaint contained legally sufficient claims to proceed.
Case Highlights Limits of Emotional Distress Claims
The lawsuit drew attention because it involved alleged workplace conduct connected to a medical speech impairment rather than physical injury claims.
Cuff alleged the employee’s comments aggravated emotional trauma connected to a traumatic brain injury. The complaint described long-term psychological effects and claimed the incident permanently affected his quality of life.
Federal courts, however, apply strict standards when evaluating emotional distress lawsuits, particularly at the pleading stage. Judges reviewing dismissal motions examine whether allegations meet established legal thresholds before allowing cases to move into discovery and trial phases.
The opinion released Thursday represented another procedural setback for Cuff after earlier amendment issues delayed the case.
Court records included in the ruling did not identify the unnamed employee allegedly involved in the phone conversation.
The current status of the case remains tied to Judge Wigenton’s ruling on Atlantic Health Systems’ motion to dismiss the operative complaint filed by Paul Cuff in the U.S. District Court for the District of New Jersey.
