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Robinson v. Hewlett-Packard Corp.

Citations: 183 Cal. App. 3d 1108; 228 Cal. Rptr. 591; 1986 Cal. App. LEXIS 1866; 48 Fair Empl. Prac. Cas. (BNA) 819Docket: H000328

Court: California Court of Appeal; July 29, 1986; California; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a former employee, Robinson, against Hewlett-Packard Corporation (HP) following a summary judgment that ruled in favor of the employer. Robinson brought forth multiple claims including breach of contract, racial discrimination, invasion of privacy, and intentional infliction of emotional distress. The court's decision to grant summary judgment in favor of HP was partially affirmed and partially reversed on appeal. The primary legal issues revolve around alleged wrongful termination, with Robinson asserting that HP breached an implied covenant of good faith and fair dealing and discriminated against him based on race. The court found insufficient evidence to support Robinson's claims of racial discrimination and invasion of privacy, as he failed to provide substantial proof to establish a prima facie case. However, Robinson's claim of emotional distress due to racial insults was considered sufficiently supported to proceed to trial. His retaliatory termination claim was dismissed due to vague allegations and lack of supporting evidence. Ultimately, the court reversed the summary judgment regarding the emotional distress claim but affirmed it in other respects, leaving each party to bear its own costs.

Legal Issues Addressed

Implied Covenant of Good Faith and Fair Dealing

Application: Robinson alleged a breach of the implied covenant of good faith and fair dealing as part of his wrongful termination claim.

Reasoning: The first cause of action, titled 'Breach of Contract,' claimed that Robinson and HP had a partially written, oral, and implied agreement, which HP breached by terminating him and violating the implied covenant of good faith and fair dealing.

Intentional Infliction of Emotional Distress

Application: Robinson's claim for emotional distress due to racial insults was deemed sufficient to create a triable issue, warranting further examination.

Reasoning: Robinson provided evidence indicating that Giovanna Rosso, his supervisor, intentionally insulted him based on his race, leading to his emotional distress.

Invasion of Privacy

Application: Robinson's claim of invasion of privacy due to surveillance by HP was not substantiated with evidence, leading to its dismissal.

Reasoning: Robinson failed to present any evidence of being followed or surveilled, leading to the conclusion that he abandoned the issue in the trial court.

Racial Discrimination and Wrongful Termination

Application: Robinson's claim of racial discrimination as a basis for wrongful termination was not supported by sufficient evidence to establish a prima facie case.

Reasoning: Robinson's claim of racial discrimination centers on his termination, which he alleges was influenced by his race as a black plaintiff.

Retaliatory Termination

Application: Robinson's claim of retaliatory termination for seeking legal counsel during performance reviews was dismissed due to lack of evidence and specificity in pleadings.

Reasoning: Robinson's mention of public policy violations was deemed too vague to constitute a valid cause of action.

Summary Judgment Standard

Application: The trial court granted summary judgment in favor of HP, which was partially affirmed and partially reversed on appeal.

Reasoning: The court's decision is partially affirmed and partially reversed.