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Case Basics
Docket No. 
(Argued the cause for the respondents)
(Department of Justice, for the United States, as amicus curiae, supporting the petitioner)
(Argued the cause for the petitioner)
Facts of the Case 

Michael A. Haddle, an at-will employee for Healthmaster, Inc., filed suit in federal court alleging his employer, along with 2 previous Healthmaster, Inc. officers, Jeanette Garrison and Dennis Kelly, conspired to have him fired in retaliation for obeying a federal grand jury subpoena and later testifying in a criminal trial against Healthmaster, Inc. for Medicare fraud. Haddle claimed his employers' acts had had "injured [him] in his person or property" in violation of federal law, specifically the Civil Rights Act of 1871. The District Court, relying on precedent, dismissed the suit for failure to state a claim. The precedent the court cited held that an at-will employee discharged pursuant to a conspiracy proscribed by the Act has suffered no actual injury because he has no constitutionally protected interest in continued employment. The Court of Appeals affirmed.


May at-will employees sue their employers over firings allegedly carried out to retaliate for testimony against their employers?

Decision: 9 votes for Haddle, 0 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1985)

Yes. In a unanimous decision, announced by Chief Justice William H. Rehnquist, the Court ruled that such interference may give rise to a claim for damages under the Civil Rights Act of 1871. "The kind of interference with at-will employment relations alleged here is merely a species of the traditional torts of intentional interference with contractual relations and intentional interference with prospective contractual relations," wrote Chief Justice Rehnquist.

Cite this Page
HADDLE v. GARRISON. The Oyez Project at IIT Chicago-Kent College of Law. 25 August 2015. <http://www.oyez.org/cases/1990-1999/1998/1998_97_1472>.
HADDLE v. GARRISON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1998/1998_97_1472 (last visited August 25, 2015).
"HADDLE v. GARRISON," The Oyez Project at IIT Chicago-Kent College of Law, accessed August 25, 2015, http://www.oyez.org/cases/1990-1999/1998/1998_97_1472.