Sheets v. Teddy's Frosted Foods

Supreme Court of Connecticut · 1980 · Contracts

ContractsEmployment at willWrongful dischargePublic policyemployment at willwrongful dischargeretaliatory dischargepublic policy

Facts

The plaintiff worked for the defendant frozen-food company from 1973 to 1977 as quality control director and later operations manager. He discovered that some vegetables were substandard and some meat components were underweight, making the company's labels false or misleading under the Connecticut Uniform Food, Drug and Cosmetic Act. In May 1977 he notified the defendant in writing and recommended corrective measures, but his recommendations were ignored. He was terminated on November 3, 1977, allegedly not for poor performance as stated, but in retaliation for trying to secure the company's compliance with the statute.

Issue

Whether an employer's otherwise general right to terminate an employee hired for an indefinite term is limited when the discharge allegedly contravenes a clear mandate of public policy. More specifically, whether an employee states a cause of action in tort by alleging that he was fired for insisting that his employer comply with the Connecticut food-labeling statute.

Rule

Although employment for an indefinite term remains generally terminable at will, an employee may state a tort claim for wrongful discharge when the dismissal violates an important public policy. At least where a relevant state statute expresses that public policy, an employer may be liable in damages for discharging an employee in retaliation for conduct aimed at securing compliance with that law.

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

Nina Patel worked for an indefinite term as compliance manager at Lakeview Nutritional Labs, a fictional supplement maker in Columbus, Ohio. After she repeatedly told senior management that the company was shipping products with labels that misstated ingredient quantities in violation of an Ohio labeling statute carrying criminal penalties, she was fired and told she was "not a team player."

If Nina sues for wrongful discharge, which is the strongest argument that her complaint should survive a motion to dismiss under the rule recognized by the majority?

Explanation. The majority recognized that although indefinite employment is generally terminable at will, an employee may state a tort claim when discharged for a demonstrably improper reason derived from an important violation of public policy. A complaint is sufficient where it alleges retaliation for efforts to secure compliance with a relevant state statute. The decision does not require a just-cause contract or an express statutory private remedy. (Derived from Sheets v. Teddy's Frosted Foods (n.d.).)