Odorizzi v. Bloomfield School Dist

In Odorizzi v. Bloomfield School Dist. (1966) 246 Cal.App.2d 123, a schoolteacher resigned under pressure from his superiors and later attempted to rescind his resignation on the ground of constructive fraud, which requires a breach of duty by one in a confidential or fiduciary relationship. The court held that ordinarily an employer-employee relationship is not itself "confidential" (Vai v. Bank of America (1961) 56 Cal.2d 329, 338 confidential relationship may exist whenever a person with justification places trust and confidence in the integrity and fidelity of another), especially where the parties were negotiating to bring about a termination of their relationship: "In such a situation each party is expected to look after his own interests, and a lack of confidentiality is implicit in the subject matter of their dealings." (Odorizzi, supra, at p. 129.)