Foley v. Interactive Data Corp. case brief

Foley v. Interactive Data Corp. case brief summary
765 P.2d 373 (1988)

CASE SYNOPSIS

Plaintiff discharged employee appealed the judgment of the Superior Court of Los Angeles County (California), which affirmed the trial court's judgment sustaining defendant employer's demurrer without leave to amend in plaintiff's suit for compensatory and punitive damages for wrongful discharge.

CASE FACTS
Plaintiff employee alleged that defendant employer wrongfully discharged him because he informed defendant that his new supervisor was under suspicion for embezzling from another company. Plaintiff asserted a tort cause of action for wrongful discharge in violation of public policy, a contract claim for breach of an implied-in-fact promise to discharge for good cause only, and tortious breach of the implied covenant of good faith and fair dealing.

DISCUSSION

• The court affirmed in part and reversed in part the sustaining of defendant's demurrer without leave to amend.
• The court held that plaintiff's tort claim for wrongful discharge failed since no public interest was involved.
• The court also held that tort remedies were not available for breach of the implied covenant of good faith and fair dealing; and that plaintiff's cause of action for breach of an implied-in-fact contract promise to discharge only for good cause survived the statute of frauds, Cal. Civ. Code §1624 (a).

CONCLUSION
The court affirmed that plaintiff's tort cause of action for wrongful discharge failed and that tort remedies were not available for breach of an implied covenant of good faith and fair dealing. The court reversed the dismissal of plaintiff 's claim for breach of an implied-in-fact contract promise to discharge only for cause.

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