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Appellant discharged employee sought damages against respondent employer arising out of his termination. The Superior Court of the City and County of San Francisco (California) ruled in favor of respondent, holding workers’ compensation was the exclusive remedy for appellant’s emotional damage claims and his economic claims, and that appellant had waived any claims for damages by signing a release. Appellant sought review of these orders.
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Overview
Appellant discharged employee brought suit against respondent former employer, alleging breach of contract, termination in violation of public policy, breach of the implied covenant of good faith and fair dealing, and infliction of emotional distress. Appellant also sought relief under Cal. Lab. Code § 3602(b)(2). The trial court granted respondent’s motions for summary judgment and dismissal on the grounds that workers’ compensation was the exclusive remedy both for appellant’s emotional damage and for his wrongful termination and contract claims. The trial court held that the release of appellant’s workers’ comp claim constituted a waiver of any civil claims. Appellant sought review. The court held that emotional distress caused by the termination of employment occurred within the course of employment, and affirmed the judgment as to appellant’s emotional damage claims. The court reversed as to appellant’s claims for economic damages, holding that the workers’ comp scheme did not preclude these claims. Nor did the release whereby appellant settled his workers’ comp claim preclude his economic and contract claims. The court remanded the case for further proceedings.
Outcome
The court affirmed the grant of summary judgment as to appellant’s emotional damage claims, holding that the exclusive remedy for these was the workers’ compensation act. The court reversed the dismissal of appellant’s economic damage claims, because these were not precluded by the act, nor by the release appellant executed in settling his workers’ compensation claim. The court remanded the case for further proceedings.
