Tag: at-will-employment

Haddle v. Garrison, 525 U.S. 121 (1998)

FACTS: Federal agents investigated Jeanette Garrison (et al.) for Medicare fraud. Michael A. Haddle, an at-will employee of Garrison, cooperated in the investigation. Haddle was also set to testify against Garrison at a grand jury. However, Haddle claims Garrison terminated his employment to deter him from testifying at the criminal trial.

PROCEDURAL HISTORY: Haddle (Petitioner) sued Garrison (Respondents) for conspiracy to deter cooperation in a criminal trial and, conspiracy to retaliate for his attendance before a grand jury. Petitioner also asserted damages under 42 U.S.C. § 1985(2) and other state claims. The district court granted the Respondents motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6). The appeals court affirmed. SCOTUS granted certiorari.

JUDGMENT: Reversed and remanded.


ISSUE: Whether a plaintiff states a claim for damages when he alleges his employer was provoked by § 1985(2), to conspire to terminate his at-will employment.

HOLDING OF THE COURT: SCOTUS held a claim for relief is stated under §1985(2) when a third-party interferes with an employee’s at-will employment relationship.

RATIONALE: SCOTUS said nothing in § 1985(2) requires a plaintiff to suffer an injury to their “constitutionally protected property interest” before they can claim damages under § 1985(2). Petitioners allegation that Respondents interfered with his at-will employment meets the definition of intentional interference with contractual relations.