Sheets v. Teddy's Frosted Foods, Inc.
179 Conn. 471 (1980)
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Rule of Law:
An employee hired for an indefinite term has a cause of action in tort for wrongful discharge if the reason for the discharge contravenes a clear mandate of public policy.
Facts:
- Emard H. Sheets was employed by Teddy’s Frosted Foods, Inc., a producer of frozen food products, as a quality control director and operations manager.
- In his capacity, Sheets observed that his employer was using substandard vegetables and underweight meat components in its frozen food products.
- These practices resulted in the company's products violating the Connecticut Uniform Food, Drug and Cosmetic Act because the labels were false and misleading.
- In May 1977, Sheets communicated his concerns in writing to the company's management and recommended corrective actions.
- Sheets' recommendations were ignored by the company.
- On November 3, 1977, Teddy's Frosted Foods, Inc. terminated Sheets' employment.
- The company stated the reason for termination was unsatisfactory performance, but Sheets alleged the true reason was retaliation for his efforts to ensure the company complied with state law.
Procedural Posture:
- Emard H. Sheets sued his former employer, Teddy's Frosted Foods, Inc., in a Connecticut trial court for wrongful discharge.
- The defendant, Teddy's Frosted Foods, filed a motion to strike the complaint, arguing it was legally insufficient to state a claim.
- The trial court granted the defendant's motion to strike.
- The plaintiff declined to plead further, and the trial court rendered a final judgment for the defendant.
- The plaintiff, Sheets, appealed the judgment to the Supreme Court of Connecticut.
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Issue:
Does an employee hired for an indefinite term have a cause of action in tort for wrongful discharge if the reason for the discharge is retaliation for his efforts to ensure his employer's compliance with a state statute?
Opinions:
Majority - Peters, J.
Yes. An at-will employee has a cognizable claim for wrongful discharge if the employee can prove a demonstrably improper reason for dismissal, the impropriety of which is derived from a violation of public policy. While contracts for an indefinite term are generally terminable at will, this right is not absolute and is subject to judicial scrutiny when its exercise violates public policy. Public policy imposes limits on an employer's discretion, especially when an employee's conduct as a good citizen is punished. Here, the plaintiff alleged he was discharged for insisting his employer comply with the Connecticut Uniform Food, Drug and Cosmetic Act, a statute with criminal penalties intended to protect public health. An employee should not be forced to choose between risking criminal sanctions for violating a statute and jeopardizing his continued employment.
Dissenting - Cotter, C. J.
No. The court should not abandon the well-established principle that an indefinite employment contract is terminable at the will of either party. Creating a new, open-ended cause of action for retaliatory discharge is a legislative function that the judiciary should not usurp, especially since the state legislature recently considered and rejected a bill to require 'just cause' for termination. The public policy at issue here is only marginally affected, as the plaintiff could have reported the alleged violations to the proper state authorities without risking his job. This decision creates a 'sword' for disgruntled employees and will open a 'Pandora's box' of unwarranted litigation, impairing employers' ability to manage their workforce.
Analysis:
This case is significant for establishing the tort of wrongful discharge in violation of public policy in Connecticut, creating an important exception to the traditional employment-at-will doctrine. It empowers employees by providing a legal remedy when they are terminated for upholding laws or other important public policies. The decision shifts some power from employers to employees in at-will situations and has led to further litigation defining the scope and sources of 'public policy' that can support such a claim.
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