Sheets v. Teddy's Frosted Foods Inc.
179 Conn. 471, 427 A.2d 385 (Conn. 1980)
Sheets worked for Teddy's
Frosted Foods. He began to notice that the company was producing
substandard foods and was violating labeling laws.
When he mentioned his
concerns to management, they fired him.
Sheets felt that he was
wrongfully discharged, and sued.
Sheets argued three things;
that there was an implied contract,
that it was a violation of public policy to fire someone for ensuring
food safety, and that it was a malicious discharge.
Sheets admitted that his
employment contract said he could be terminated at-will, but that he
argued that couldn't be fired for something that violates public policy.
To do so is a tort.
The Trial Court found for
Teddy's and dismissed the case. Sheets appealed.
The Trial Court found that
Sheet's employment contract said he could be fired at will, so Teddy
didn't violate any of Sheet's contractual rights.
The Connecticut Supreme Court
reversed and remanded for trial.
The Connecticut Supreme
Court found that the Trial Court erred when they only considered the case
from the breach of contract perspective.
The Court found that the
tort claim was sufficient to remand the case for trial.
The Court recognized an
exception to the traditional rules governing employment-at-will so as to
permit cause of action for wrongful discharge where the discharge
contravenes a clear mandate of public policy.
The Court noted that claims
involving mandates of public policy are actionable, ordinary disputes
between employees and employers are not.
Sheets' job as quality
control supervisor exposed him to possible liability and criminal
prosecution if he helped cover up the violations.
Since Sheets was forced to
choose between possibly going to jail and staying employed, he had a
case, and should get a trial.
In a dissent it was argued
that this decision gave the employees the ability to coerce employers into
not firing them.
The dissent argued that this
decision invited the unrestricted use of an allegation of almost any
statutory or even regulatory violation by an employer as the basis for
cause of action by a discharged employee.
The dissent argued that the
Connecticut Legislature had considered Whistleblower laws, but had not
enacted any (as of the date of this trial). Therefore, who were the
Courts to create laws that the legislature had failed to enact?
There are plenty of statutory
categories (race, age, gender) that would override an employment at-will
contract. Sheets didn't have a particular statute he could point to that
put him in a protected category. However, the fact that protected categories
existed makes it possible to accept Sheets' argument.
In theory, if this case had
gone the other way, other people in Sheets' position would not report
violations of health codes, and the State has an interest in wanting
people to report health violations.