Haddle v. Garrison [II]

119 S.Ct. 489 (1998)

What's Going On?

Petitioner appeals from the dismissal of his claim for damages against his former employer for failure to state a claim upon which relief may be granted.

Who's Who?

Petitioner      :

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

Respondents :

Jeanette Garrison, Dennis Kelly – (original defendant) officers of Healthmaster Home Health Care, Inc.

Facts:

A federal grand jury indictment charged Respondents Jeanette Garrison and Dennis Kelly, officers of Healthmaster Home Health Care, Inc., with Medicare fraud. Petitioner Michael A. Haddle, a former at-will employee of Healthmaster Home Health Care, Inc., cooperated with federal agents in the investigation preceding the indictment, and was also expected to testify as a witness in the criminal trial resulting from the indictment. Respondents were barred from participating in Healthmaster's affairs, but allegedly conspired with one of Healthmaster's remaining officers to terminate Petitioner's employment in an effort to intimidate and retaliate against Petitioner for his assistance with the federal court proceedings. Petitioner sued Respondents for damages in federal district court under 42 U.S.C. § 1985(2), a federal statute that proscribes, in part, conspiracy to deter a witness from testifying in federal court and provides for damages where conspirators cause injury to the person or property of a potential witness. The court dismissed the suit pursuant to FRCP 12(b)(6) for failure to state a claim upon which relief may be granted. The court held that an at-will employee who is dismissed pursuant to a conspiracy proscribed by § 1985(2) has no cause of action because an at-will employee has no constitutionally protected interest in continued employment. The court therefore concluded that Petitioner's discharge did not constitute an actual injury under the statute. The Supreme Court granted certiorari.

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:

Yes. A dismissal pursuant to FRCP 12(b)(6) requires the court in review to assume that the facts as alleged in Petitioner's complaint are true. The harm alleged by Petitioner is third-party interference with an at-will employment relationship. The district court held that Petitioner must have suffered a constitutionally protected property interest in order to state a claim for damages under § 1985(2); however, harm suffered as a result of a conspiracy to intimidate or retaliate is the wrong upon which § 1985(2) focuses. The fact that employment at-will is not property for the purposes of the Due Process Clause does not preclude the loss of such employment from being an injury under § 1985(2). Third-party interference with at-will employment has long been compensable under tort law and therefore gives rise to a claim for damages under § 1985(2). Reversed and remanded.

Basic Rule:

The fact that employment at-will is not property for the purposes of the Due Process Clause does not preclude the loss of such employment from being an injury under 42 U.S.C. § 1985(2).

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