Williams v. Cobb County Farm Bureau Inc.

To support a claim of age discrimination, a plaintiff must show that, but for his age, he would not have been fired, and the plaintiff's former employers testified that their sole consideration for firing the plaintiff was an offensive e-mail that he sent to other employees.

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Charles Williams appeals from the trial court’s grant of summary judgment to Cobb County Farm Bureau, Russell Smith, and Georgia Farm Bureau Mutual Insurance Company. Williams sued Georgia Farm Bureau Mutual Insurance Company for age discrimination under the Age Discrimination in Employment Act ADEA; sued Russell Smith for intentional infliction of emotional distress, invasion of privacy, and tortious interference with employment relations; sued both Cobb County Farm Bureau and Georgia Farm Bureau Mutual Insurance Company as vicariously liable for the acts and omissions of defendant Smith; and, sued for punitive damages against all defendants. After reviewing the record, we conclude that defendants were entitled to summary judgment on Williams’s claims and affirm. The record shows that Williams was a district sales manager for Georgia Farm Bureau Mutual Insurance Company “company”. Russell Smith is a radio broadcaster and a farmer. He serves as a volunteer member of the board for the Cobb County Farm Bureau. Cobb County Farm Bureau is a not-for-profit corporation that provides various services to Georgia Farm Bureau Mutual Insurance Company. The company pays a fee to Cobb County Farm Bureau in exchange for office space, management and clerical support.

This case arose when Williams was asked to help develop a plan to increase the sale of life insurance policies for the company. A meeting to present the plan was scheduled and was attended by representatives from the different Georgia Farm Bureaus around the State. Russell Smith attended as a representative from the Cobb County Farm Bureau. George Hoyle, one of Williams’s co-workers made the presentation. After the presentation, several people expressed displeasure with the life insurance plan.

Williams v. Cobb County Farm Bureau Inc.

To support a claim of age discrimination, a plaintiff must show that, but for his age, he would not have been fired, and the plaintiff's former employers testified that their sole consideration for firing the plaintiff was an offensive e-mail that he sent to other employees.

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