Rulon-Miller v. IBM Corp. Case Brief Summary | Law Case Explained



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Rulon-Miller v. IBM Corp. | 162 Cal. App. 3d 241, 208 Cal. Rptr. 524 (1984)

Virginia Rulon-Miller was a stellar employee with a great track record. Could her boss fire her for dating a competitor’s employee? Her wrongful-discharge claim is the subject of Rulon-Miller versus International Business Machines.

Rulon-Miller was a marketing manager for International Business Machines Corporation, or I B M. Her job performance received top reviews. She was dating Matt Blum, a former I B M employee who’d moved to a competitor company. Rulon-Miller’s boss, Phillip Callahan, knew about her relationship with Blum before he promoted her to manager.

A memo from I B M’s former chairman, Tom Watson, stated that managers shouldn’t inquire into an employee’s off-duty conduct unless the employee’s job performance was affected. The memo also said that off-duty behavior was grounds for employee dismissal only if it threatened a legitimate interest of the company. I B M had a policy prohibiting conflicts of interest but didn’t prohibit employees from socializing with competitors.

A week after Rulon-Miller received a merit raise, Callahan called her into his office. Callahan asked Rulon-Miller whether she was dating Blum. She objected to the question. Callahan warned her that she had a conflict of interest and said he’d fire her if she didn’t break up with Blum. He told her she had a few days to think about it.

The next day, Callahan fired her. He said he was making the decision for her.

Rulon-Miller sued I B M for wrongful discharge and intentional infliction of emotional distress. After a trial, the jury awarded her one hundred thousand dollars in compensatory damages, and two hundred thousand dollars in punitive damages. I B M appealed to the California Court of Appeal.

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