Frampton v. Central Indiana Gas Company
297 N.E.2d 425, 63 A.L.R. 3d 973, 260 Ind. 249 (1973)
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Rule of Law:
An at-will employee who is discharged solely for exercising a statutorily conferred right, such as filing a claim under the Workmen’s Compensation Act, has a cause of action for retaliatory discharge against the employer.
Facts:
- Plaintiff was an employee of the Defendant.
- Plaintiff injured her arm while working, and Defendant paid her medical expenses and salary during a four-month recovery.
- Approximately 19 months after the injury, Defendant was notified that Plaintiff had suffered a 30% permanent loss in the use of her arm.
- Hesitant for fear of losing her job, Plaintiff filed a workmen's compensation claim for her permanent partial disability.
- Plaintiff received a settlement for her injury claim.
- Approximately one month after the settlement, Defendant discharged Plaintiff from her employment without providing a reason.
Procedural Posture:
- Plaintiff-employee filed a complaint against her former employer in the Henry Circuit Court (trial court) for retaliatory discharge.
- The trial court dismissed the complaint for failure to state a claim upon which relief can be granted.
- Plaintiff, as appellant, appealed the dismissal to the First District Court of Appeals.
- The Court of Appeals affirmed the trial court's dismissal.
- Plaintiff then petitioned for transfer to the Indiana Supreme Court, which granted the petition.
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Issue:
Does an at-will employee who alleges they were discharged for filing a workmen's compensation claim have a legally recognized cause of action for retaliatory discharge?
Opinions:
Majority - Hunter, J.
Yes. An employee who alleges they were discharged for filing a claim under the Workmen's Compensation Act has stated a claim upon which relief can be granted. The public policy behind the Workmen's Compensation Act is to provide an exclusive remedy for injured workers and shift the economic burden of work-related injuries from the employee to the employer. This policy would be undermined if employers could penalize employees for exercising their statutory right to compensation. The fear of being discharged would deter employees from filing just claims, effectively relieving employers of their statutory obligation. The court interpreted a provision in the Act prohibiting any 'device' that relieves an employer of its obligations to include the threat of retaliatory discharge. This creates a public policy exception to the general rule of at-will employment, which ordinarily allows an employer to discharge an employee for any reason or no reason.
Analysis:
This decision established a significant public policy exception to the long-standing doctrine of at-will employment in Indiana. By recognizing the tort of retaliatory discharge, the court provided a new protection for employees and placed a limit on an employer's previously unfettered discretion to terminate employment. This case paved the way for future claims of wrongful discharge based on other public policy violations, such as firing an employee for jury service or for refusing to commit an illegal act. It represents a judicial shift toward balancing the power between employers and employees by safeguarding statutory rights from employer coercion.
