Legal Memorandum: Fraudulent Inducement of Employment

Issue: To what extent does Minnesota 181.64 protect against false statements to induce employment?

In Vaidyanathan v. Seagate U.S. LLC, CIV. NO. 09-1212 DWF/JSM (D. Minn. Mar. 11, 2011), the plaintiff alleged that Seagate made misrepresentations that induced him to accept a “yield engineer” position with Seagate and move from Texas to Minnesota, when in fact no yield engineer position existed.*FN1  He was terminated nine months after accepting the job.  Vaidyanathan asserted a claim under § 181.64 and a common-law promissory estoppel claim.  The court dismissed the promissory estoppel claim with prejudice, but the statutory claim went to the jury.  The jury found that Seagate made a knowingly false representation to Vaidyanathan about the kind or character of the work that he would perform, and awarded him $1.9 million in damages.  Seagate appealed.  Id.*FN2

On appeal, Seagate argued that no reasonable jury could have found that it misrepresented the kind or character of work that Vaidyanathan would perform, and that the plaintiff’s argument to the contrary depended entirely on his own assumptions.  Id.  The court disagreed, finding that the jury was permitted to accept Vaidyanathan’s testimony that he never performed the specific technical job responsibilities that were identified on the job description Seagate provided (though the court itself was not that impressed with the evidence).  Id.  Vaidyanathan had testified that Seagate made knowingly false statements to him in a written job description, during interviews, and in a written job offer.  For example, Vaidyanathan pointed out that the title of the job he was […]