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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When the doctrine was transplanted to the United States, however, it resumed its unconditional classical form. Weiner, supra, 457 N.Y.S.2d at 196 n. 4, 443 N.E.2d at 443-44 n. 4 (citations omitted). In this country, its genesis can be traced to an 1877 treatise by Horace G. Wood on the master-servant relationship,1 and the doctrine came to be known as Wood’s Rule. See 82 Am.Jur.2d Wrongful Discharge § 2, at 670-71 (1992 & Supp.1997); Berube, supra, 771 P.2d at 1040; see also Judge Ferren’s opinion, ante at 168 & n. 18. In Martin v. New York Life Ins. Co., 148 N.Y. 117, 119, 42 N.E. 416, 417 (1895), the New York Court of Appeals repudiated the common law’s “one year” presumption and “uncritically embraced the at-will rule as framed by Wood.” See Berube, supra, 771 P.2d at 1041.

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