In Livitsanos v. Superior Court (1992) 2 Cal.4th 744, the primary issue was whether "purely 'emotional'" injuries were outside the scope of the workers' compensation scheme where no physical injury is alleged. (Id. at p. 750.) The Supreme Court held that "the 'physical' versus 'emotional' dichotomy is logically insupportable. More importantly, it is contrary to the text and purposes of the workers' compensation law." (Id. at p. 752.) The Court reaffirmed the rule that employer misconduct is outside the workers' compensation remedy only when it "exceeds the normal risks of the employment relationship . . . ." (Id. at p. 756.) The Court expressed no opinion on whether the employer's alleged actions (including deliberately false allegations of embezzlement) were outside the normal bounds of the employment relationship, noting that "the circumstances of the discharge were further complicated by the fact that plaintiff apparently occupied a dual status in his relationship with defendants: as employee, and as independent distributor of Continental's product." (Ibid.)