Lewis v. Equitable Life Assurance Soc'y of the United States

The Equitable Life Assurance Society of the United States (the Company) hired Carole Lewis, Mary Smith, Michelle Rafferty, and Suzanne Loizeaux (plaintiffs) as dental-claim approvers. The plaintiffs worked in the St. Paul office for several months. The Company then dispatched the plaintiffs to its Pittsburgh office for two-week periods to provide assistance. The Company did not provide the plaintiffs with detailed instructions regarding expense reports for their travel. Instead, the plaintiffs were given a travel advance of $1,400 each, told of the Company’s daily allowances for meals and maid tips, and told to keep receipts for hotel bills and airfare. The plaintiffs each spent the travel advance in full. When the plaintiffs returned to St. Paul, the Company commended them on their job performance. However, the Company also informed them that they were required to submit expense reports detailing daily expenditures during the travel. The plaintiffs filled out the expense reports, but the Company required the plaintiffs to revise the reports twice. The plaintiffs complied, but the Company again directed the plaintiffs to revise the reports. The plaintiffs then refused to make further changes. The Company sent the plaintiffs each a letter with a completely different set of guidelines for expense reports and directed the plaintiffs to revise the reports. The plaintiffs refused. The Company terminated the plaintiffs for gross insubordination. The plaintiffs sought other employment, but prospective employers required the plaintiffs to disclose the reasons for leaving their previous positions. The plaintiffs disclosed that they had been terminated for gross insubordination and encountered difficulties in obtaining new jobs. The plaintiffs sued the Company for defamation. The jury awarded the plaintiffs compensatory and punitive damages, and the court of appeals affirmed the finding of liability. The Company petitioned the Minnesota Supreme Court for review.