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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From October 1991 until she was fired in March 1992, Linda Carl was employed as a part-time nurse in the Neonatal Intensive Care Unit ("NICU") of Children's Hospital. Shortly thereafter, Ms. Carl filed this suit against the hospital and Cathy Fonner, a nurse employed by the hospital as a clinical educator, alleging that she had been discharged because of her advocacy for patients' rights before the legislature and the courts. Ms. Carl claimed specifically that she was fired because she had testified before the Council of the District of Columbia on proposed tort reform legislation, taking a position contrary to the interests of her employer,[1] and because she had appeared in court as an expert witness for plaintiffs in medical malpractice cases. She sought recovery on six separate theories: wrongful discharge, promissory estoppel, defamation, intentional infliction of emotional distress, breach of contract, and intentional interference with contractual relations. With respect to the wrongful discharge claim, Ms. Carl asserted that her termination contravened specific public policies recognized in the District of Columbia. This court's prior decision summarized these claimed policies as follows:

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