In March 2010, plaintiff Scott Widder, a claim section manager for State Farm Fire and Casualty Co., was terminated from employment. According to State Farm, Widder was terminated after an investigation revealed that Widder had engaged in misconduct. However, at the time of his termination, Widder was on a leave of absence with pay after requesting a transfer accommodation due to a bout of depression. Widder sued his employers, State Farm Fire and Casualty Co., State Farm Mutual Insurance Co., and State Farm General Insurance Co.; and the claims manager for State Farm who oversaw Widder, Jeanne Dietrich. Widder alleged that the defendants’ actions constituted wrongful termination, a breach of implied contract/implied covenant, disability discrimination, a failure to accommodate, a failure to engage in the interactive process, workplace harassment, and retaliation. Widder also filed a separate claim for defamation, and the matters were ultimately consolidated. Several of the plaintiff’s claims were dismissed on summary judgment and the defamation claim was dismissed without leave to amend, following the sustaining of a demurrer. Thus, the matter proceeded to trial on Widder’s claims against only State Farm Fire and Casualty Co. for breach of implied contract/implied covenant, failure to accommodate, and failure to engage in the interactive process. Widder claimed that he was a good employee during his time with State Farm, but that when he started suffering from depression, he dealt with adverse employment actions, including harassment in the workplace and receiving a negative performance evaluation. He further claimed that State Farm failed to accommodate his request for a transfer and that his termination was an act of retaliation. State Farm denied all of Widder’s accusations, and claimed that Widder was not discriminated against or harassed. It also claimed that although Widder was a good employee for a period of time, his performance deteriorated and he ultimately engaged in misconduct that led to his termination., Widder claimed that he suffered a loss of earnings as a result of his wrongful termination, as well as suffered emotional distress from the incident. Thus, Widder sought recovery of $2.3 million in total economic damages for his loss of earnings, and three-to-five times that amount in non-economic damages for his emotional distress. Defense counsel contended that Widder was owed zero economic damages because he was terminated for legitimate business reasons. Counsel further contended that neither State Farm’s actions nor Widder’s termination caused Widder any emotional distress, and that his claim for non-economic damages was without merit.