Anderson

Introduction

Plaintiff Pauline Anderson (Pauline) appeals from an order of dismissal entered after the trial court sustained demurrers to her causes of action for negligent infliction of emotional distress and loss of consortium. These claims arose from the allegedly wrongful termination of her husband Roger E. Anderson (Roger) by defendant Northrop Corporation (Northrop). We find that Pauline failed to set forth facts establishing she was a direct victim of Northrop’s assertedly tortious conduct and that Roger did not suffer sufficient mental or physical harm to significantly impair their marital relationship. Accordingly, we affirm.

Factual and Procedural Background

In 1977 Roger accepted employment with Northrop and was assigned to perform his duties as technical language instructor and supervisor in Saudi Arabia. With Northrop’s knowledge, Pauline relocated with him. Seven and one-half years after the Andersons’ apparently successful settlement in Saudi Arabia, Northrop terminated Roger, allegedly without cause and in violation of its own policies and regulations as well as California statutory and decisional law. On December 2, 1985, the Andersons brought suit:…