A patent attorney sued his former employer for having fired him after he complained about the smoke in his office.  The trial court dismissed his petition, which included a count for infliction of emotional distress.  The Court of Appeals reversed the dismissal, saying that “an employee is protected against discharge or discrimination for complaining in good faith about working conditions or practices which he reasonably believes to be unsafe.”

138 Cal.App.3d 290, 188 Cal. Rptr. 159, (1982).