The general rule is that the tort of intentional infliction of emotional distress, in essence, requires the defendant's conduct to be so extreme and outrageous as to go beyond all possible bounds of decency, and to be regarded as atrocious and utterly intolerable in a civilized community.
Respondent Virginia Rulon-Miller was a low-level marketing manager at International Business Machines (IBM) in its office products division in San Francisco. When she started working for the company, she was told that career opportunities were available to employees as long as they are performing satisfactorily and were willing to accept new challenges. It was widely known within the organization that Rulon-Miller was dating Matt Blumm, an employee of IBM’s competitor. The company knew about the relationship even before Rulon-Miller was appointed as manager, and it seemed that none of her superiors raised any issue of conflict regarding the relationship. However, in 1979, her immediate supervisor Phillip Callahan dismissed her from her job because of the alleged conflict of interest brought about by her relationship with one of the competitor’s employees. Subsequently, Rulon-Miller instituted a claim against Callahan and IBM (collectively, petitioners), alleging wrongful discharge and intentional infliction of emotional distress, to which the trial court awarded her punitive and compensatory damages. On appeal, the petitioners contended that the trial court erred in allowing the jury to consider the issue of wrongful discharge and argued that Rulon-Miller was not discharged but reassigned.
Was Rulon-Miller wrongfully discharged from International Business Machines (IBM)?
The Court held that substantial evidence supported the jury verdict that Rulon-Miller was wrongfully discharged. The Court noted that Rulon-Miller, when questioned about her relationship, invoked her right to privacy under a company policy that insured employees’ right to hold a job despite off-the-job-behavior. Also, it found that Rulon-Miller did not even have access to confidential information and could not have conveyed such to a competitor, thus the discharge was made in bad faith. The Court found that Callahan’s conduct was so outrageous and extreme that punitive damages for emotional distress were appropriate. Accordingly, the judgment was affirmed.