In Gibbs v. Consolidated Services (2003) 111 Cal.App.4th 794, the plaintiff brought an action for age discrimination, wrongful termination, and intentional infliction of emotional distress, and the trial court granted the employer's motion for summary judgment. (Id. at pp. 796-797.) In 1992, the plaintiff was promoted from a driver to an operations manager. (Id. at p. 797.) After the company was restructured in 1999, the plaintiff's supervisor told him that he lacked the skills to continue as an operations manager and terminated his employment. (Id. at p. 798.) In response, the plaintiff asked for a driver's position. (Ibid.) His supervisor stated that there were no such positions even though a driver's position did exist. (Ibid.) The plaintiff argued that the employer's reason for terminating him was a pretext for age discrimination because the employer failed to give him a position as a driver. (Id. at p. 800.) The appellate court rejected this argument, stating that "when an employer modifies its workforce for business reasons, it has no obligation to transfer an employee to another position within the company. " (Ibid.)