Hansen

Appellant Aerospace Defense Related Industry District Lodge 725 of the International Association of Machinists and Aerospace Workers (appellant) is a subordinate unit of a labor union that represents aerospace workers. Respondents Robert Hansen and Marla Des Ermia are two former employees of appellant who pursued wrongful termination claims against it. Their cases were consolidated prior to trial. Hansen obtained a jury verdict in the amount of $335,000 plus punitive damages of $17,782. Des Ermia was awarded $368,000 plus punitive damages in the amount of $17,782. Appellant appeals. We reverse the judgments.

Factual and Procedural Background

Des Ermia

Des Ermia was a clerical employee in appellant’s Burbank office. In January 1996, she called appellant’s regional office and reported that her office manager, Barbara Powley, had made unauthorized purchases with her union credit card. Appellant’s president, Calvin Duncan, reported the matter to the union office and an independent investigator was assigned to the matter. The investigator subsequently concluded that Powley had not intentionally misused the union credit card. Duncan, however, suspended Powley for 30 days…