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In California, a corporate employer cannot be liable for punitive damages for wrongful termination unless an officer, director or managing agent:
In White v. Ultramar, Inc., the California Supreme Court ruled that the mere ability to hire and fire employees does not elevate a supervisory employee to a position of managing agent for the corporation. “Managing agent” includes only those corporate employees who exercise substantial independent authority and judgment in their corporate decision making. Further, their decisions ultimately determine corporate policy. The scope of a corporate employee’s discretion and authority under this definition is a question that must be decided on a case-by-case basis.2
1. Civ. Code sec. 3294 (b)
2. White v. Ultramar, Inc., 21 Cal. 4th 563 (1999)