Gantt v. Sentry Insurance

In September 1979, Vincent Gantt (plaintiff) was hired as a sales manager for the Sacramento office of Sentry Insurance (Sentry) (defendant). In 1980, Joyce Bruno was hired to work in Sentry’s Sacramento and Walnut offices. Bruno reported to both Gantt and Gary Desser, the manager of the Walnut office. Soon after she began working, Bruno informed Gantt that Desser was sexually harassing her. Gantt reported the harassment to Sentry headquarters, but no action was taken. After Gantt made a second report of the harassment, Sentry demoted Desser and eventually fired Bruno. Bruno filed a complaint against Sentry with the Department of Fair Employment and Housing (DFEH). Sentry’s in-house counsel, Caroline Fribance, began investigating Bruno’s complaint and discussed the matter with Gantt. Although Gantt felt that Fribance was pressuring him not to disclose to the DFEH that he had reported the harassment to Sentry headquarters, Gantt nevertheless disclosed the truth to the DFEH investigator. Approximately two months later, Sentry demoted Gantt to a sales-representative position. Sentry also refused to give Gantt a book of accounts, which severely limited his ability to perform his job. Gantt resigned and sued Sentry, alleging that Sentry had constructively discharged him in retaliation for his refusal to withhold truthful testimony from the DFEH investigator, which was in violation of public policy. The trial court found that Gantt’s discharge violated public policy. The court of appeal affirmed. Sentry appealed.