Kaye

INTRODUCTION

A former law librarian whose employer discharged him after he sent a scathing e-mail criticizing his superiors appeals the trial court’s decision to grant summary adjudication as to the state law causes of action in his wrongful termination action. We conclude the granting of summary adjudication was proper under the circumstances and affirm the judgment.

I

FACTUAL AND PROCEDURAL BACKGROUND

In late February 2006, a representative from the Administrative Office of the Courts (AOC) contacted the San Diego County Public Law Library (Library) seeking a panel member for a program about helping self-represented litigants with appeals. The program was part of an AOC conference on self-represented litigants. A Library staff member referred the representative to Michael Kaye, a reference librarian who taught the Library’s appellate course for self-represented litigants. The AOC representative asked Kaye to be a panel member. Because Kaye’s supervisor, Joan Alien-Hart, was on sick leave that week, Kaye requested permission to participate in the program from Robert Riger, the Library’s director and Alien-Hart’s supervisor. Riger immediately approved Kaye’s request.…