McKnight v. Simpson's Beauty Supply, Inc.
1987 N.C. App. LEXIS 2717, 358 S.E.2d 107, 86 N.C. App. 451 (1987)
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Rule of Law:
A contractual requirement for an employee to perform to the "reasonable satisfaction" of an employer requires the employer's dissatisfaction to be objectively reasonable, not arbitrary. Additionally, while expert medical testimony is not essential to prove common emotional distress, a claim for intentional infliction of emotional distress (IIED) fails if the employer's conduct, such as an abrupt and causeless firing, does not meet the high standard of being legally "outrageous."
Facts:
- A plaintiff employee and a defendant employer entered into a written employment contract for a two-year term.
- The contract stipulated that the employee must perform his duties 'to the reasonable satisfaction of employer.'
- The contract also specified it could be terminated early only if the employee became unable to perform the work or failed or refused to do so.
- After a few months, the defendant employer terminated the plaintiff's employment.
- The defendant claimed it was dissatisfied with the plaintiff's work.
- The plaintiff contended that he performed his work properly and was discharged without just cause.
- The termination was abrupt and unexplained, causing the plaintiff to be 'shocked' and 'upset'.
Procedural Posture:
- The plaintiff employee sued the defendant employer in a trial court for breach of contract and intentional infliction of emotional distress (IIED).
- The trial court directed a verdict in favor of the defendant on the IIED claim, dismissing it.
- The jury heard the breach of contract claim and returned a verdict in favor of the plaintiff.
- The defendant, as appellant, appealed the judgment on the breach of contract claim to the Court of Appeals of North Carolina.
- The plaintiff, also as an appellant, cross-appealed the trial court's dismissal of his IIED claim to the same appellate court.
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Issue:
First, does a contract requiring performance 'to the reasonable satisfaction of employer' require the employer's dissatisfaction to be objectively reasonable? Second, is an abrupt, causeless, and unexplained firing sufficiently 'outrageous' conduct to sustain a claim for intentional infliction of emotional distress?
Opinions:
Majority - Phillips, Judge
Yes, a contract requiring performance to the employer's 'reasonable satisfaction' requires the employer's dissatisfaction to be objectively reasonable, and no, an abrupt and causeless firing, without more, is not sufficiently 'outrageous' to support a claim for intentional infliction of emotional distress. Regarding the contract claim, the phrase 'reasonable satisfaction' imposes an objective standard. This means the employer cannot terminate the employee based on capricious or unreasonable dissatisfaction; it must show that its dissatisfaction was justified and based on the employee's actual performance. Because the employee presented evidence that he performed his duties properly, the question of whether the employer's dissatisfaction was reasonable was a factual issue for the jury. On the emotional distress claim, the trial court erred by requiring expert medical testimony to prove common feelings like being 'shocked' and 'upset.' However, this error was not prejudicial because the plaintiff's claim failed on another essential element: the defendant's conduct was not 'outrageous.' An abrupt, unexplained, and causeless firing, while sufficient for a breach of contract claim, does not rise to the level of extreme and outrageous conduct required by law for the tort of intentional infliction of emotional distress, as established in precedents like Dickens v. Puryear.
Analysis:
This decision clarifies two distinct areas of employment law in North Carolina. First, it establishes that 'reasonable satisfaction' clauses in employment contracts are not a blank check for employers; they impose an objective, good-faith standard that can be reviewed by a jury, thereby protecting employees from arbitrary dismissal. Second, the ruling reinforces the high threshold for proving intentional infliction of emotional distress in the employment context. By distinguishing a breach of contract (wrongful termination) from the separate tort of IIED, the court signals that terminated employees will generally be limited to contract damages unless the employer's conduct is exceptionally egregious, far surpassing the act of the termination itself.
