Rulon-Miller v. IBM Corp.
California Court of Appeal
162 Cal. App. 3d 241, 208 Cal. Rptr. 524 (1984)
Virginia Rulon-Miller (plaintiff) was a low-level manager responsible for selling typewriters and office equipment for International Business Machines Corporation (IBM) (defendant). Rulon-Miller was in a relationship with Matt Blum, a former IBM account manager who had left to work for an IBM competitor. The fact that Rulon-Miller and Blum were dating was well known throughout the IBM organization. Rulon-Miller performed well at her job and was given a merit-based raise in 1979. One week after the raise, Rulon-Miller’s manager, Phillip Callahan, inquired about her relationship with Blum. Rulon-Miller asserted her right to privacy based on IBM’s employment policies. An IBM memorandum that had been circulated to IBM managers stated that IBM was only concerned with an employee’s off-the-job behavior if the behavior interfered with the employee’s ability to perform or seriously affected the reputation of IBM. IBM also had policies governing conflicts of interest. These policies regulated employees’ moonlighting activities and employees’ associations where the activities or associations affected the employees’ ability to exercise good judgment. IBM did not have any policies specifically regulating romantic relationships with the employees of its competitors. Callahan asserted that Rulon-Miller’s relationship with Blum was a conflict of interest and consequently terminated Rulon-Miller’s employment. Rulon-Miller sued for wrongful discharge and intentional infliction of emotional distress. The jury in trial court found in favor of Rulon-Miller. IBM appealed.
Rule of Law
Holding and Reasoning (Rushing, J.)
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