Giancarlo Incalza v. Fendi North America, Inc.

We consider whether, in this case, the Immigration Reform and Control Act of 1986 (IRCA) preempts California labor laws that forbid employers from firing an employee without good cause. We also consider whether the district court abused its discretion in denying defendant’s motion for a new trial. In both instances, our answer is No.

I. FACTUAL AND PROCEDURAL HISTORY

In June of 1990, Giancarlo Incalza, a native and citizen of Italy with two years of business education, began working as a sales associate for Fendi in Rome. Approximately six months after his employment started, Fendi offered him a sales position in its New York City store. Paola Fendi, the head of the company, assured him that his employment would be secure as long as he continued to perform well. Incalza ac cepted the offer and moved to the United States on an E-l visa secured with Fendi’s assistance.

Incalza worked at Fendi’s New York store from 1990 until 2000. During this period, the company renewed his visa several times. Management also made further assurances to him regarding his job security.

In August, 2000, Incalza was promoted to manager of Fendi’s Beverly Hills store. During his tenure in Beverly…