BAKES, Chief Justice.
John and Juanita Evans brought suit against Twin Falls County and several deputy sheriffs alleging, inter alia, claims under 42 U.S.C. § 1983 for violation of their constitutional rights, assault and battery, false arrest and interference with contract. The Evanses' claim of damages was primarily for emotional distress. Subsequently, Juanita Evans died, and the complaint was amended to substitute "the Estate of L. Juanita Evans,"...
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