Yau stated a cause of action for WTVPP against SM Ford by alleging that it terminated him because he complained to his superiors that his supervisor and coworkers were submitting fraudulent warranty claims. Slip op. at 10-18. If true, Yau’s allegations "could be construed" as complaints of potential violations of criminal statutes proscribing theft and fraud.
Yau did not state a cause of action for IIED, which he alleged only against the individual defendants. Slip op. at 19-21. The claim was barred by the exclusivity provisions of the Workers’Compensation Act. California law no longer recognizes an exception for emotional distress caused by conduct that violates a fundamental public policy.
The opinion is available here.