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Fowler v. Varian Associates, Inc.

Citations: 196 Cal. App. 3d 34; 241 Cal. Rptr. 539Docket: H002087

Court: California Court of Appeal; November 8, 1987; California; State Appellate Court

Narrative Opinion Summary

The case involves a dispute between a former employee, Fowler, and his previous employer, Varian Associates, Inc. Fowler sued Varian for wrongful termination, breach of contract, and intentional infliction of emotional distress after he was effectively discharged for engaging with a competitor, Omega. The lower court granted summary judgment in Varian's favor, and the appellate court affirmed this decision. Fowler's involvement with Omega, including attendance at investor meetings and refusing to disclose details to Varian, was deemed a breach of loyalty. The court held that Varian had good cause for termination based on Fowler's actions, aligning with legal standards that employee disloyalty justifies dismissal. Fowler's claims of wrongful termination in violation of public policy were dismissed, as no public policy supports assisting a competitor. His emotional distress claim failed due to a lack of evidence of outrageous conduct by Varian. The court found that the confidentiality agreement addendum proposed by Varian was not unreasonable. The judgment was affirmed, with the Supreme Court denying further review, and the court emphasized that Fowler's actions did not meet the threshold for either wrongful termination or emotional distress under applicable legal standards.

Legal Issues Addressed

Breach of Duty of Loyalty

Application: Fowler's involvement with Omega, a competitor, was found to breach his duty of loyalty to Varian, justifying his dismissal.

Reasoning: Fowler's actions, particularly his close involvement with Omega, a direct competitor, constituted a breach of his duty of loyalty, providing grounds for his dismissal.

Confidentiality Agreements and Business Practices

Application: Varian's request for an addendum to the confidentiality agreement was deemed permissible and not a violation of section 16600.

Reasoning: Fowler did not contest Varian's confidentiality agreement addendum under section 16600, and protecting proprietary information through such agreements is permissible.

Good Cause for Termination

Application: The court held that employee disloyalty constitutes sufficient grounds for termination, supporting Varian's decision to discharge Fowler.

Reasoning: Fowler's claim that the determination of 'good cause' cannot be made at the summary judgment stage is incorrect, as established precedent supports that employee disloyalty constitutes sufficient grounds for termination.

Intentional Infliction of Emotional Distress

Application: The court found no evidence of extreme and outrageous conduct by Varian that would support Fowler's emotional distress claim.

Reasoning: Fowler failed to show any evidence of extreme and outrageous behavior that exceeds societal norms.

Public Policy and Employment Law

Application: Fowler's claim of wrongful termination in violation of public policy was rejected as no established public policy permits assisting a competitor.

Reasoning: No established public policy permits an employee to assist a competitor of their employer.

Summary Judgment Standards

Application: The appellate court affirmed the summary judgment, as no material fact was in dispute and Varian was entitled to judgment as a matter of law.

Reasoning: The appellate court affirmed the lower court's decision, stating that summary judgment is appropriate when no material fact is in dispute and the moving party is entitled to judgment as a matter of law.