Martinez v. Rite Aid
This appeal arises out of an employment discrimination case brought by plaintiff Maria Martinez against her former employer, defendant Rite Aid Corporation, and her former supervisor, defendant Kien Chau. Martinez alleged that, during her employment with Rite Aid, she was subjected to unlawful discrimination, harassment, and retaliation based on her disability, age, medical leave of absence, and complaint about sexual harassment. Following a lengthy trial, the jury found in favor of Martinez on her claims for wrongful termination in violation of public policy, intentional infliction of emotional distress, and invasion of privacy, and awarded Martinez $3.4 million in compensatory damages and $4.8 million in punitive damages. In their appeal, Rite Aid and Chau assert numerous legal errors, including challenges to the sufficiency of the evidence supporting the jury’s special verdicts as to both liability and damages. In her cross-appeal, Martinez argues the trial court abused its discretion in denying her motion for leave to further amend her complaint to add statutory claims for violations of the California Fair Employment and Housing Act (FEHA).
We conclude that the evidence was sufficient to support the verdicts in favor of Martinez on her causes of action for wrongful termination in violation of public policy and intentional infliction of emotional distress, but not on her cause of action for invasion of privacy. We further conclude that the verdicts awarding compensatory damages to Martinez must be reversed because they were impermissibly ambiguous, and the verdict awarding punitive damages to Martinez must be reversed because the evidence was insufficient to support the imposition of punitive damages liability against Rite Aid for the acts of its employees. Finally, we conclude that the trial court did not abuse its discretion in denying Martinez leave to file a third amended complaint. We accordingly reverse and remand the matter for a new trial on the issue of compensatory damages as to Martinez’s causes of action for wrongful termination in violation of public policy and intentional infliction of emotional distress.
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