Utah Court of Appeals: Employee Caught on Camera Taking a Customer’s Wallet had no Actionable Claim against Employer

The Utah Court of Appeals upheld a trial court’s summary judgment dismissal of a former employee’s claim against Target for breach of contract, intentional and negligent infliction of emotional distress, and defamation.  In a twenty page opinion, the court said that the employee, who had been caught on camera taking a customer’s wallet, had no contractual right to progressive discipline before being discharged, had not been treated outrageously when interrogated by a security officer who had already decided to discharge her before questioning her, and had not been defamed because Target had a conditional privilege to communicate the reason for the discharge with its employees and interested parties.