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?
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.
Decisions
Decision: 9 votes for Haddle, 0 vote(s) against Legal provision: Reconstruction Civil Rights Acts (42 USC 1985)
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Full Opinion by Justice William H. Rehnquist
