(dissenting).
I respectfully dissent from divisions II and III of the majority’s opinion and the result. I would hold that emotional distress is not a recoverable element of damages in a retaliatory discharge case or, at the very least, that such emotional distress must be severe to be recoverable.
An important objective of allowing a tort action for retaliatory discharge is to encourage job security, especially for those workers employed at will. The elements of damages for the action should be fashioned to reflect that objective. See Vigil v. Arzola, 102 N.M. 682, 699 P.2d 613, 620-21 (App.1983) (recognizing employee’s tort action for retaliatory discharge but disallowing emotional distress as a recoverable element of damages). As the Vigil court stated, “What is at stake is job security, not reparation for every conceivable ill.” Id. I believe that in Iowa a discharged worker’s feelings are adequately protected by our recognition of an action for outrageous infliction of emotional distress in the employment context. See, e.g., Northrup v. Farmland Industries, Inc., 372 N.W.2d 193, 197-99 (Iowa 1985).
If we are to allow emotional distress as an element of damages in retaliatory discharge cases, however, I would at least require that the distress be severe before such damages are awarded. The tort law should encourage a certain level of mental toughness; every inconsiderate and unkind act cannot be compensable. Northrup, 372 N.W.2d at 198-99. Requiring that a plaintiff’s harm be severe and genuine would establish some reasonable end to liability for an employer’s wrongful discharge of an employee. Cf. Barnhill v. Davis, 300 N.W.2d 104, 107 (Iowa 1981) (recognizing tortfeasor’s liability to a bystander who suffers “serious” mental distress, which ordinarily would be mental distress accompanied by physical manifestations of the distress).
I would hold that damages for emotional distress are not available in a retaliatory discharge case. At the very least, such *358emotional distress should be severe to be recoverable as an element of damages. Therefore, I dissent.