Supreme Court of Vermont
Leslie G. Boulton v. CLD Consulting Engineers, Inc.
August 29, 2003175 Vt. 413
Summary
The Court affirmed summary judgment for CLD on Boulton's claims for wrongful termination, breach of the implied covenant of good faith and fair dealing, gender discrimination, and intentional infliction of emotional distress. It held that CLD gave Boulton adequate warning of concerns about her management performance, that the alleged covenant was not breached, that she offered no evidence of gender-based disparate treatment or pretext, and that CLD's conduct was not sufficiently outrageous. The Court also held that the challenged evidence concerning management's reasons for employee resignations was not hearsay and, in any event, was unnecessary to sustain summary judgment.