Reynolds started work in 1999 as a sales representative for Ethicon. In 2002, she was assigned to a new division, selling medical equipment for bariatric weight-loss surgery. She was based in Sioux Falls, South Dakota, and covered sales in the region. Soon after she began that assignment, the company reviewed the sales territories and determined that the Sioux Falls region was weak.
A week after Reynolds told Burns, her supervisor, that she was pregnant, he met with her and told her the Sioux Falls office would be closed and offered her the Louisville office or a severance package.
She was later also offered the St. Louis office.
Several weeks later, Reynolds suffered a miscarriage.

1. The appeals court held Reynolds had no grounds to sue for infliction of mental distress. Does she have grounds for any other tort?
2. Did the employer have an obligation to be more careful in how Reynolds was treated due to her pregnancy?