Geary v. United States Steel Corp.
319 A.2d 174, 1974 Pa. LEXIS 511, 456 Pa. 171 (1974)
Rule of Law:
An at-will employee has no right of action against an employer for wrongful discharge where the complaint discloses a plausible and legitimate reason for the termination and no clear mandate of public policy is violated.
Facts:
- George B. Geary was employed as a salesman by United States Steel Corporation (company) from 1953 to 1967 in an at-will capacity.
- Geary believed a new tubular casing product sold by the company was unsafe and had not been adequately tested.
- He communicated his misgivings to his immediate superiors, who instructed him to "follow directions."
- Despite this instruction, Geary bypassed his superiors and presented his concerns about the product to a company vice-president.
- Following Geary's actions, the company reevaluated the product and withdrew it from the market.
- Shortly thereafter, United States Steel Corporation summarily discharged Geary.
Procedural Posture:
- George B. Geary filed an amended complaint in trespass against United States Steel Corporation in the Court of Common Pleas of Allegheny County (trial court).
- United States Steel Corporation filed preliminary objections in the nature of a demurrer, seeking to dismiss the complaint.
- The trial court sustained the demurrer and dismissed the complaint with prejudice.
- Geary (as appellant) appealed the dismissal to the Superior Court of Pennsylvania (intermediate appellate court).
- The Superior Court affirmed the trial court's order per curiam, without a written opinion.
- Geary (as appellant) then appealed to the Supreme Court of Pennsylvania, which granted allocatur (discretionary review).
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Issue:
Does an at-will employee have a non-statutory cause of action for wrongful discharge against his employer when he is terminated after raising safety concerns about a new company product directly to upper management?
Opinions:
Majority - Mr. Justice Pomeroy
No. An at-will employee does not have a cause of action for wrongful discharge when the complaint itself suggests a plausible, legitimate reason for termination and violates no clear mandate of public policy. The court reaffirmed the traditional at-will employment doctrine, under which an employer can terminate an employee for any or no reason. Geary's complaint failed to allege a specific intent to harm him, which is necessary for a tort based on malicious motive. The court inferred that the company discharged Geary not for his safety concerns, but because he bypassed his superiors and disrupted the company's internal administrative order, which constitutes a legitimate business reason. The court declined to create a broad public policy exception for product safety whistleblowing by a salesman, expressing concern about overburdening the judicial system and inhibiting employers' legitimate personnel judgments.
Dissenting - Mr. Justice Roberts
Yes. An employee should have a cause of action for an arbitrary and retaliatory discharge that offends public policy. The dissent argues that Geary's discharge violated two clear public policies: the prevention of injury from dangerous products and an employee's duty to communicate critical information to his employer. Firing Geary for fulfilling his duty to protect the public and the company from a defective product was an arbitrary and illogical exercise of employer power. The majority's fear of increased litigation is an inappropriate reason to deny relief, and the common law should evolve to protect unorganized employees from such abusive dismissals.
Analysis:
This decision strongly reaffirms the employment-at-will doctrine in Pennsylvania, setting a high bar for wrongful discharge claims. By refusing to recognize a public policy exception for an employee who reported safety concerns, the court signaled its reluctance to judicially create broad exceptions to the doctrine. The ruling emphasizes an employer's prerogative to maintain internal order and make personnel decisions, even if those decisions appear unfair. This case establishes that for a wrongful discharge claim to succeed, the employee must show either a specific intent to harm or a violation of a very clear and compelling public policy, a standard not met by an employee's good-faith efforts to ensure product safety.
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