A defendant, knowing a neighbor is profoundly afraid of snakes, releases a non-venomous garden snake into the neighbor's open window as a prank. The defendant does not intend to cause psychiatric harm, but he is aware that his actions carry a high risk of triggering a severe emotional breakdown. The neighbor suffers a major depressive episode as a result. In a jurisdiction following the majority rule for Intentional Infliction of Emotional Distress (IIED), which of the following best describes the defendant's liability?