Wednesday, December 18, 2013

Locke v. Warner Bros., Inc. case brief

Locke v. Warner Bros., Inc. case brief summary
66 Cal. Rptr. 2d 921 (1997)


CASE SYNOPSIS
Appellant director sought review of a decision of the Superior Court of Los Angeles County (California) that granted summary judgment in favor of respondent entertainment studio. Appellant brought the action for tortious wrongful discharge in violation of the public policy against sex discrimination, breach of contract, and fraud.

CASE FACTS
Appellant director brought action against respondent entertainment studio for tortious wrongful discharge in violation of the public policy against sex discrimination, breach of contract, and fraud. Summary judgment was granted in favor of respondent, and appellant sought review.

DISCUSSION

  • In reversing the decision, the court held that a triable issue existed as to whether respondent breached its contract with appellant by failing to evaluate appellant's proposals on their merits. 
  • If respondent acted in bad faith by categorically rejecting appellant's work and refusing to work with her, irrespective of the merits of her proposals, such conduct was not beyond the reach of the law. 
  • The implied covenant of good faith and fair dealing obligated respondent to exercise its discretion honestly and in good faith. 
  • Testimony indicated that respondent expressed an absolute unwillingness to work with appellant, it could have reasonably been inferred that respondent never intended to give appellant's proposals a good faith evaluation.
  • Respondent's payment of the guaranteed compensation under the agreement did not establish that respondent fulfilled its contractual obligation.
CONCLUSION
The court reversed the decision that granted summary judgment in favor of respondent entertainment studio, holding triable issues of fact were present with respect to appellant director's claims of breach of contract and fraud. The court ruled that the evidence presented inferred respondent breached the agreement by refusing to consider appellant's proposals in good faith, and the issue of fraudulent intent was one for the trier of fact.

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