Rulon-Miller v. IBM Corp.
California Court of Appeal
162 Cal. App. 3d 241, 208 Cal. Rptr. 524 (1984)
- Written by Jamie Milne, JD
Facts
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 left to work for an IBM competitor. The relationship was well known throughout IBM, including to Rulon-Miller’s manager, Phillip Callahan, before Rulon-Miller was promoted to manager. Rulon-Miller performed well and was given a significant merit-based raise in 1979. One week later, Callahan told Rulon-Miller that her relationship with Blum was a conflict of interest and that she had a few days to choose between Blum and her job. Rulon-Miller asserted her right to privacy based on IBM’s employment policies. An IBM memorandum circulated to IBM managers stated that IBM was concerned with an employee’s off-the-job behavior only if the behavior interfered with the employee’s ability to perform or seriously affected IBM’s reputation. IBM also had policies governing conflicts of interest. These policies regulated employees’ moonlighting activities and employees’ associations if the activities or associations affected the employees’ ability to exercise good judgment. IBM did not have any policies specifically prohibiting romantic relationships with the employees of its competitors. The next day, Callahan told Rulon-Miller that he had made up her mind for her and, upon her protestations, terminated her employment. Rulon-Miller sued for wrongful discharge and intentional infliction of emotional distress (IIED). The trial-court jury held in Rulon-Miller’s favor, awarding both compensatory and punitive damages. IBM appealed.
Rule of Law
Issue
Holding and Reasoning (Rushing, J.)
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