Archer v. Farmer Bros. Co.

Richard Archer worked for Farmer Bros. Company (Farmer) (defendant) for 22 years and had not been absent from work even once in eight years. Archer was being investigated for possible misconduct when he had a serious issue with his heart, which Farmer believed was a heart attack. Archer had been out on authorized sick leave for five days when Farmer’s vice president of sales ordered Archer’s supervisors, Dennie Rawson and Al Henshaw (defendants), to find Archer and terminate him. When Rawson and Henshaw resisted, the vice president cursed and told them that he did not care whether Archer was on his deathbed and that they had better fire Archer. Rawson and Henshaw then found Archer at his mother-in-law’s home, barged in without invitation, entered a bedroom where Archer was lying in bed half-dressed, and announced that he was terminated. Although Archer was under investigation for possible misconduct, he was a skilled manager nearing retirement and was completely shocked by his termination. Archer’s physician stated that Archer’s health was in such a fragile state that his termination could have caused Archer a deadly heart attack. Archer did not have a doctor’s note authorizing his return to work. Later that evening, Archer tried to kill himself. Archer sued Farmer, Rawson, and Henshaw successfully for intentional infliction of severe emotional distress for their outrageous conduct. A jury awarded Archer damages, including exemplary damages. A trial judge denied the defendants’ motions for a directed verdict and for judgment notwithstanding the verdict. Farmer, Rawson, and Henshaw appealed. On appeal, the defendants argued that the trial court should have dismissed Archer’s claim related to outrageous conduct because his termination fell under workers’ compensation. Further, the defendants argued that their motions should have been granted because their conduct was not outrageous or intended to cause emotional harm. Finally, the defendants objected to the award of exemplary damages.