Skip to main content
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

1,123 chars
In deference to our previous wrongful discharge cases, Ms. Carl does not seek to invoke the "very narrow exception" to the at-will doctrine that we articulated in Adams. She concedes that her case does not fall within this exception. Ms. Carl also does not contend that the hospital's alleged retaliatory firing of her was conduct prohibited by D.C.Code § 1-224. Instead, she reiterates the argument she made before the division "that the statute embodies a broader legislative disapproval of any acts that punish an individual for testifying before the Council." Carl I, 657 A.2d at 289 n. 5. Thus she now invites the en banc court, as she invited the division, "to expand Adams to encompass a claim such as the one alleged by her, arguing that [section 1-224], the national nursing code, and District of Columbia case law set forth clear public policy, the violation of which creates a wrongful discharge cause of action." Id. at 289. For the reasons that follow, I agree with Ms. Carl with respect to her reliance upon section 1-224, but I reject her other arguments. B. The proper standard for a public policy exception