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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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

Other Sections in This Document (617)

Full Text

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The employment-at-will doctrine should be no exception to the power of each panel of this court to do justice within the confines of precedent and legal reasoning. Prior to today, no other three-judge panel has failed to at least implicitly address the merits of expanding or creating a public policy exception to the employment-at-will doctrine. See, e.g., Elliott v. Healthcare Corp., 629 A.2d 6, 8-9 (D.C.1993) (rejecting expansion of public policy exception to employment-at-will doctrine); Nolting v. National Capital Group, Inc., 621 A.2d 1387 (D.C.1993) (same); Smith v. Union Labor Life Ins. Co., 620 A.2d 265, 269 (D.C.1993) (same); Sorrells v. Garfinckel’s, Brooks Brothers, Miller & Rhoads, Inc., 565 A.2d 285 (D.C.1989) (same). Three of these cases were decided after Gray and do not suggest that a panel is prohibited from recognizing a public policy exception; each rather rejects the need for an expansion on the facts of each ease. In fact, the only exception to the employment-at-will doctrine in this jurisdiction was adopted by an opinion of a three-judge panel, not the court en banc. Adams, supra (recognizing an exception for at-will employment doctrine when employee refuses to violate the law). II.