Wanland

Los Gatos Lodge, Inc. (the Lodge) appeals from a judgment entered on a jury verdict of $150,000 in favor of Carolyn Wanland in her action for constructive wrongful termination. The Lodge contends plaintiff’s action is preempted by federal labor law and asserts error in several of the trial court’s evidentiary rulings and in the giving of a punitive damage instruction to the jury. Plaintiff cross-appeals, urging error in a ruling in limine excluding evidence she contends was pertinent to her claim that two other employees of the Lodge intentionally interfered with her employment contract. We find no reversible error and therefore affirm.

Factual Background

Carolyn Wanland began working for the Lodge in October 1980 as a front desk clerk. In time she became the assistant to the Lodge’s catering manager and then was named director of sales and marketing. When the catering manager retired, in April 1985, plaintiff was promoted to that position.

At the outset of her employment at the Lodge, plaintiff joined the Hotel-Motel Restaurant Employees and Bartenders Union, Local 19 (the Union). As a front desk clerk, plaintiff was covered by the terms of a collective bargaining…