English v. General Electric Co.

Facts

Vera English worked as a laboratory technician at General Electric’s nuclear-fuels production facility in Wilmington, North Carolina from 1972 to 1984. In February 1984, she complained to GE management and the Nuclear Regulatory Commission about perceived nuclear safety violations, including co-workers’ failure to clean radioactive material spills. Frustrated by GE’s inaction, English deliberately failed to clean a uranium-contaminated work table, instead marking the contaminated areas with red tape to make them conspicuous. Days later, she called her supervisor’s attention to the still-uncleaned areas, halting work for inspection and cleaning. GE charged English with knowingly failing to clean radioactive contamination, temporarily reassigned her, and informed her she would be laid off unless she found another position within ninety days. English was terminated on July 30, 1984, after failing to secure alternative employment. She filed administrative complaints and subsequently brought a diversity action in federal court alleging wrongful discharge and intentional infliction of emotional distress, claiming GE removed her under guard, assigned degrading work, derided her as paranoid, barred her from controlled areas, placed her under surveillance, isolated her from coworkers, and conspired to charge her fraudulently.