Haddle v. Garrison

Unpublished Opinion. Docket No. 96-00029-CV-1 (S.D. Ga. 1996)

What's Going On?

Defendant's motion to dismiss pursuant to FRCP 12(b)(6), for failure to state a claim upon which relief may be granted, in Plaintiff's action for damages against Defendant, his former employer.

Who's Who?

Plaintiff        :

Michael A. Haddle – former at-will employee of Healthmaster Home Health Care, Inc.

Defendants  :

Garrison, et al – officers of Healthmaster Home Health Care, Inc.

Facts:

Plaintiff, a former at-will employee of Healthmaster Home Health Care, Inc., claims that his employment was improperly terminated in order to impede his participation as a witness in a federal criminal trial. Plaintiff brought suit seeking damages under 42 U.S.C. § 1985(2)[, a federal statute that proscribes, in part, conspiracy to deter a witness from testifying in a federal court and provides for damages where conspirators cause injury to the person or property of a potential witness]. Defendant moves to dismiss pursuant to FRCP 12(b)(6) for failure to state a claim upon which relief may be granted.

Issue:

May an at-will employee bring an action for wrongful termination under a statute that requires a plaintiff to suffer an actual injury prior to bringing a suit?

Decision:

Under FRCP 12(b)(6), a defendant may move to dismiss a complaint on the grounds that the plaintiff has failed to state a claim upon which relief can be granted. In assessing the merits of a Rule 12(b)(6) motion, a court may only dismiss a complaint if, assuming all factual allegations of the complaint are true, it is clear that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief. In order for a cause of action to arise under § 1985(2), a plaintiff must have suffered an actual injury. In this case, Plaintiff's termination does not constitute an actual injury under § 1985(2) because, as an at-will employee, Plaintiff had no constitutionally protected interest in continued employment. Plaintiff has therefore failed to state a claim upon which relief can be granted. Dismissed.

Basic Rule:

In assessing the merits of an FRCP 12(b)(6) motion, a court may only dismiss a complaint if, assuming all factual allegations of the complaint are true, it is clear that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.

Terms:

At-will :

Able to be terminated without cause.

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