Sheets
worked for Teddy's Frosted Foods.He began to notice that the company was producing substandard foods
and violated labeling laws.They fired him.He
felt that he was wrongfully discharged, and sued.
Sheets
felt there was an implied contract, there was a violation of public
policy, and it was a malicious discharge.
Sheets
did not argue that he couldn't be terminated at-will, but that he couldn't be fired for something
that violates public policy.To do so is a tort.
Teddy's
filed a motion to strike the complaint as legally insufficient (a demure).The Trial Court struck the complaint based on the fact that no one
argued that Sheets couldn't be fired at-will.Sheets appealed.
The
Connecticut Supreme Court remanded the case for further proceeding.
The
Court only considered the case from the breach of contract perspective.
The
Court felt that the tort claim was sufficient to remand the case for
trial.
The
Court had to consider whether to recognize an exception to the
traditional rules governing employment-at-will so as to permit cause of
action for wrongful discharge where the discharge contravenes a clear
mandate of public policy.
Claims
involving mandates of public policy are actionable, ordinary disputes
between employees and employers are not.
Sheets'
job as quality control supervisor exposed him to possible liability and
criminal prosecution if he helped cover up the violations.
Since
Sheets was forced to chose between prosecution and continued employment,
he had a case, and should get a trial.
There
was a dissent who felt that this case gave the employees the ability to
coerce employers into not firing them.
The
dissent felt that this decision invited the unrestricted use of an
allegation of almost any statutory or even regulatory violation by an
employer as the basis for cause of action by a discharged employee.
The
dissent claimed that the Connecticut Legislature had considered
Whistleblower laws, but had not enacted any (as of the date of this
trial).Therefore, who were
the Courts to create laws that the legislature had failed to enact?
There
are plenty of statutory categories (race, age, gender) that would override
an employment at-will contract.Sheets didn't have a particular statute he could point to that put
him in a protected category.However, the fact that protected categories existed makes it
possible to accept Sheets' argument.
In
theory, if this case had gone the other way, other people in Sheets'
position would not report
violations of health codes, and the State has an interest in wanting
people to report health violations.
