In Haney v. Aramark Uniform Services, Inc. (2004) 121 Cal.App.4th 623, a former employee alleged his employment was terminated in violation of public policy, because he was discharged for complaining about and refusing to implement fraudulent billing practices. Summary judgment was not appropriate, the Court of Appeal held, because there was no evidence demonstrating that Haney's acts were sufficiently linked with group action, or authorized by his coworkers, to constitute concerted action subject to federal preemption. (Haney, supra, 121 Cal.App.4th at pp. 629, 638-639.) The court also ruled that the public policy of discouraging fraud was sufficient to support his claim for discharge in violation of public policy. (Id. at pp. 629, 642-643.) In Haney v. Aramark Uniform Services, Inc. (2004) the employer was engaged in the business of providing rental services. (Id. at p. 629.) The employee, who worked for the employer as a route sales representative, alleged that the employer "used a number of techniques that resulted in its customers paying for products or services that they did not receive and that these billing practices were fraudulent." (Id. at p. 630.) The employee alleged his employment was terminated after he objected to the employer's "practice of overcharging and misleading customers, and he refused to follow the employer's practice of defrauding them." (Id. at pp. 641-642.) The employee sued the employer for wrongful termination in violation of public policy referring to, inter alia, Penal Code section 484 defining theft. (121 Cal.App.4th at pp. 631, 642.) The employer in Haney moved for summary adjudication arguing, inter alia, that the employee's wrongful termination in violation of public policy cause of action "did not assert an appropriate public policy to support the claim." (Haney, supra, 121 Cal.App.4th at p. 631.) The appellate court reversed summary judgment granted in favor of the employer, stating, "in light of Tameny v. Atlantic Richfield Co. (1980) 27 Cal.3d 167 and the fact that theft through fraudulent representation or pretense has long been defined as a crime by statute in California, we conclude that when an employer discharges an employee who refuses to defraud a customer, the employer has violated a fundamental public policy and may be liable in tort for wrongful discharge." (Haney, at p. 643.) The Haney court further stated, "the employee's allegations that he was terminated for complaining about and refusing to engage in fraudulent billing practices are sufficient to state a claim for retaliatory discharge in violation of a public policy." (Ibid.)