Carl v. Children's Hospital, 702 A.2d 159 (1997)

Citation: Carl v. Children's Hospital, 702 A.2d 159 (1997)
Parent Document: Carl v. Children's Hospital, 702 A.2d 159 (1997)
Jurisdiction: DC (municipal)
Effective Date: 1997-09-23
Original Source: https://www.courtlistener.com/opinion/2395626/carl-v-childrens-hospital/ ↗

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This court has not had occasion to interpret D.C.Code § 1-224, nor is it called upon to do so here. In particular, we need not conclude—and would be hard-pressed to conclude—that Children’s Hospital violated this criminal statute when it fired Ms. Carl. Rather, in determining whether a public policy exception to the at-will doctrine applies to this case, we need only decide whether the alleged firing because Ms. Carl testified before the Council is sufficiently within the scope of the policy embodied in the statute so that a court may consider imposing liability on Children’s Hospital for Ms. Carl’s termination for otherwise permissible reasons. Although the question is not an easy one to answer, I think the statute speaks with sufficient clarity to entitle Ms. Carl to proceed beyond a motion to dismiss her complaint under Rule 12(b)(6). In the context of this case, I read section 1-224 as a declaration of policy by the Council seeking to ensure the availability of information essential to its legislative function by imposing criminal penalties on anyone who seeks to impede Council access to such information.

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