Threat To Terminate Employee May Constitute Extortion

Proskauer - California Employment Law
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Proskauer - California Employment Law

Galeotti v. International Union of Operating Eng’rs Local No. 3, 2020 WL 2188995 (Cal. Ct. App. 2020)

John Galeotti, a former business agent for the union, alleged he was wrongfully terminated for refusing to contribute money toward the campaigns of various union officials who had run for election to union positions. Galeotti alleged his employment was terminated after he failed to contribute $1,000 to the union officials’ campaign; among other things, he alleged extortion under Penal Code §§ 484 and 518. The trial court sustained the employer’s demurrer and dismissed the claims, but the Court of Appeal reversed, holding that Galeotti properly alleged a “threat” to “injure his property” (i.e., the termination of his employment) within the meaning of the extortion statute.

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