Cauthorne v. King

30 Va. Cir. 202, 1993 Va. Cir. LEXIS 16
CourtRichmond County Circuit Court
DecidedFebruary 19, 1993
DocketCase No. LU-3114-3
StatusPublished
Cited by2 cases

This text of 30 Va. Cir. 202 (Cauthorne v. King) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cauthorne v. King, 30 Va. Cir. 202, 1993 Va. Cir. LEXIS 16 (Va. Super. Ct. 1993).

Opinion

BY JUDGE T. J. MARKOW

This case is before the court on demurrer to Count II of the motion for judgment, motion to strike or reduce punitive damages, and motion to strike the jury demand.

This action stems from defendants' alleged discriminatory treatment of black applicants for housing and termination of employees for protesting that treatment. Defendants in this action are Herbert S. King, Sr., an individual with ownership interests in a number of apartment complexes in the Richmond area, King Properties, a corporation of which King is Director and President, and Kings Point Associates, a partnership in which King and/or King Properties are partners. Plaintiffs are Lisa Cauthorne and Patricia Noack, two individuals who were employed by King Properties, and Housing Opportunities Made Equal (“HOME”), a nonprofit corporation which counsels clients about residential opportunities and attempts to eliminate discriminatory housing practices in Richmond. Plaintiffs’ allegations, taken as true for purposes of the demurrer, reveal the following facts.

Plaintiffs Cauthorne and Noack, during their employment with defendants, had responsibility for taking rental applications and discussing applicants with defendant King. The discriminatory practices King [203]*203allegedly engaged in include requiring Cauthorne and Noack to inform him of the race of applicants, making disparaging comments about black applicants, denying black applicants or requiring higher security deposits of them, steering black applicants from certain properties and limiting their access to others. Cauthorne and Noack complained to King about his practices, which resulted in King’s swearing at them, engaging in other abusive behavior, demanding they not question him, and ultimately firing them.1 Cauthorne and Noack have suffered damages as a result of their termination, and HOME has suffered damage to its organization as a result of King’s practices. It is under this fact scenario that the court considers defendants’ motions.

Demurrer to Count II

Defendants argue that plaintiffs’ Count II, a claim for wrongful discharge, should be dismissed because plaintiffs have a remedy under the Fair Housing Law, and therefore there are no grounds for an exception to the at-will employment doctrine. The controlling case in this area is Bowman v. State Bank of Keysville, 229 Va. 534 (1985), which involved a shareholder’s right to vote free from duress or fear of reprisal. The plaintiff employees in that case worked for a bank and also held a number of shares of the bank’s stock. Before a vote on a proposed merger, plaintiffs were told that if their shares were not voted in favor of the merger and the merger did not go through, their employment would be terminated, and that even if the merger did go through but their shares had been voted against it, their jobs would be adversely affected. Id. at 537. Plaintiffs voted in favor of the merger but later told the bank president that their proxies had been illegally obtained and were therefore void. Id. at 538. Plaintiffs were both terminated and sought recovery for wrongful discharge. Defendants asserted that plaintiffs were at-will employees and therefore had no cause of action for wrongful discharge; they argued that no statutory exceptions to the at-will employment doctrine applied and that any new ones had to be made by the General Assembly and not the court. Id. The court dis[204]*204cussed exceptions to the at-will doctrine which came into play when employees were terminated in violation of established public policy. Id. at 539-540. The court noted that plaintiffs had been given a statutory right to vote without fear of reprisal, that this right was in furtherance of established public policy, and that the employment at-will doctrine would not protect defendants attempting to violate this right. Id.

In the case at bar, under the Fair Housing Law, plaintiffs can exercise their own rights and aid or encourage others to exercise their rights without threat or intimidation. See Va. Code Ann. § 36-96.5 (Michie Supp. 1992). Additionally, the Fair Housing Law provides both rights and remedies, allowing for complaints to the Real Estate Board as well as civil actions. See Va. Code Ann §§ 36-96.9 and 36-96.18 (Michie Supp. 1992). The public policy exception recognized in Bowman contemplated the absence of another remedy; in fact, the court posed the issue as “whether this employer can, with absolute immunity, dischaige these employees in retaliation for the proper exercise of rights as stockholders.” Bowman, 229 Va. at 539. The court characterized the public policy exception as narrow; it was needed in that case “[i]n order for the goal of the statute to be realized and the public policy fulfilled.” Id. at 540.

In the present case, the statute has in place its own mechanisms, the complaints or civil actions mentioned above, to foster its goals and the public policy of fair housing practices. In Pruitt v. Johnston Memorial Hospital, Inc., 21 Va. Cir. 188 (1990), the plaintiff had recourse under the Virginia Safety Act and was therefore denied a public policy exception to the at-will employment doctrine. In that case, as here, the plaintiff “obviously had a statutory remedy available to her,” so the court was not required to supply another. Id. at 189. At oral argument, counsel for the plaintiffs herein asserted that if plaintiffs’ evidence at trial fails to put them squarely within the language of the Fair Housing Law and the court had previously dismissed the wrongful dischaige count, they would then be left without a remedy. This, it was argued, would be contrary to the broad public policy against discriminatory housing practices, and therefore the wrongful discharge count should stand. However, the rationale of Bowman ensures that plaintiffs have a remedy; it does not guarantee their recovery under that remedy. Plaintiffs must be afforded a mechanism to enforce their statutory- rights; if that mechanism is not provided in the statute itself, the court may [205]*205fashion one, such as the public policy exception to the at-will employment doctrine. But if a statutory remedy is available, the court need not provide alternative remedies to protect the plaintiff who may not succeed under the statute. Plaintiffs in this case have a remedy under the Fair Housing Law, and seek that remedy in Count I of their motion for judgment. The court need not allow the wrongful discharge count to stand as a safety net in the event plaintiffs do not succeed on Count I. The Fair Housing Law embodies the public policy against housing discrimination upon which plaintiffs rely; it also provides the remedy to enforce that policy, which plaintiffs pursue in Count I. As such, there is no reason to call upon the narrow exception to the employment at-will doctrine allowing a wrongful discharge claim. Therefore, defendants’ demurrer to Count II is sustained.

Motion to strike or reduce punitive damages

Defendants argue that plaintiffs’ allegations are insufficient to support a claim of punitive damages or, in the alternative, that if the punitive claim is allowed to stand, it must be limited to the $350,000 cap set out in Virginia Code § 8.01-38.1.

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Cite This Page — Counsel Stack

Bluebook (online)
30 Va. Cir. 202, 1993 Va. Cir. LEXIS 16, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cauthorne-v-king-vaccrichmondcty-1993.