This was a case about alleged emotional distress. The plaintiff claimed that a man was harassing her (in word rather than deed) so much so that his conduct was beyond the bounds of decency and "utterly intolerable in a civilized community." While some people's behavior does indeed seem worthy of criminalization, this is what the court had to say:
"No pressing social need requires that every abusive outburst be converted into a tort; upon the contrary, it would be unfortunate if the law closed all the safety valves through which irascible tempers might legally blow off steam."
from the Massachusetts District court in Boyle vs. Wenk