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Haddle v. Garrison

Supreme Court of the United States · 1998 · Civil Procedure

Civil ProcedureRule 12(b)(6)motion to dismissat-will employmentconspiracy42 U.S.C. § 1985(2)§ 1985(3)Rule 12(b)(6)

Facts

Haddle was an at-will employee of Healthmaster, Inc. After cooperating with federal investigators and appearing pursuant to a subpoena before a federal grand jury, he was expected to testify in the related criminal trial. He alleged that respondents conspired with another Healthmaster officer to cause his termination in order to intimidate him and retaliate against him for attending federal-court proceedings. He then sought damages under § 1985(2), alleging he had been injured in his person or property.

Issue

Whether a plaintiff can state a damages claim under 42 U.S.C. § 1985(2) by alleging that a conspiracy prohibited by that statute induced his employer to terminate his at-will employment. More specifically, the question was whether termination of at-will employment constitutes an injury to person or property under the statute.

Rule

Under 42 U.S.C. § 1985(2), a plaintiff need not allege injury to a constitutionally protected property interest in order to seek damages. Loss of at-will employment caused by a conspiracy to intimidate or retaliate against a federal witness or party can constitute being 'injured in his person or property' because third-party interference with at-will employment relations is a traditionally compensable tort injury.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel worked as an at-will bookkeeper for Lakeview Diagnostics in Cleveland, Ohio. She alleges that two company officers agreed with a third manager to get her fired because she had appeared under subpoena before a federal grand jury and was expected to testify at a related federal criminal trial; she was then terminated.

The officers move to dismiss Nina's § 1985(2) damages claim, arguing that because her employment was terminable at will, she suffered no injury to person or property. How should the court rule?

Explanation. The majority held that a plaintiff states a damages claim under § 1985(2) by alleging that a prohibited conspiracy induced termination of at-will employment. The statute does not require loss of a constitutionally protected property interest; traditional tort injury, including third-party interference with at-will employment relations, is enough.