Case v. State Farm Mutual Automobile Ins. Co

Brief Fact Summary. Plaintiff, a former independent contractor, sued Defendants, insurance companies, and Plaintiff’s employers for wrongful termination of his employment contract. The contract stated that it could be terminated for any or no reason. The trial court granted Defendant’s motion to dismiss for failure to state a claim upon which relief can be granted, which Plaintiff appealed.

Synopsis of Rule of Law. A complaint must allege facts that can be reasonably interpreted to state a claim for the relief that the plaintiff has requested.

Facts. Case (Plaintiff) filed a complaint against his former employers (Defendants) alleging that Defendants “interfered and meddled” with Plaintiff’s exercise of his employment contract by telling Plaintiff that he would no longer be able to perform services for Defendants if he ran for a county office. The contract stated that it could be cancelled “with or without cause.” Plaintiff requested compensatory and punitive damages. The District Court granted Defendants’ motion to dismiss and Plaintiff appealed.

Issue. Shall a lawsuit be dismissed if the clear and unambiguous language of a complaint cannot be reasonably interpreted to state a claim for the relief that the plaintiff has requested?

Held. Yes. The District Court’s order granting Ds’ motion to dismiss is affirmed. Plaintiff did not allege how Defendants could have breached a contract that could be cancelled for any or no reason. Plaintiff’s allegations also do not show an independent basis for his claim. Although courts should not dismiss a claim if there is a possible claim for relief, courts are not under a duty to make up claims that are not alleged in the complaint. The plaintiff has a right to amend his complaint once. The District Court would have given the plaintiff an additional opportunity to amend the complaint even after it had been dismissed. Therefore, the plaintiff had opportunities to correct the defects in his complaint but did not do so.

Discussion. A complaint that clearly and unambiguously alleges facts that do not state a claim for relief or does not tie the facts to the relief requested is defective and should be dismissed.