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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Among the public policy exceptions recognized by courts that allow an employee to sue for retaliatory discharge include: (1) jury duty, e.g., Nees v. Hocks, 272 Or. 210, 536 P.2d 512 (1975); (2) whistle blowing or threatened reporting of a statutory violation, e.g., Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (1980); Boyle, supra; McQuary v. Bel Air Convalescent Home, Inc., 69 Or.App. 107, 684 P.2d 21 (1984); (3) cooperating with a law enforcement investigation, e.g., Palmateer v. International Harvester Co., 85 Ill.2d 124, 52 Ill. Dec. 13, 421 N.E.2d 876 (1981); Flesner v. Technical Communications Corp., 410 Mass. 805, 575 N.E.2d 1107 (1991); (4) exercising a statutory right or privilege such as filing a worker's compensation claim, e.g., Niesent v. Homestake Mining Co., 505 N.W.2d 781 (S.D.1993); (5) exercising a constitutional or political right such as refusing to participate in employer's lobbying effort and privately stating opposition to company's political stand or running for political office, e.g., Novosel v. Nationwide Ins. Co., 721 F.2d 894 (3d Cir.1983); Davis v. Louisiana Computing Corp., 394 So.2d 678 (La.Ct.App.), writ denied, 400 So.2d 668 (La.1981); (6) acting consistently with a professional code of ethics, e.g., Pierce, supra; Kalman v. Grand Union Co., 183 N.J.Super. 153, 443 A.2d 728 (App.Div.1982); (7) being fired because of race or gender, e.g., Lockhart v. Commonwealth Educ. Sys. Corp., 247 Va. 98, 439 S.E.2d 328 (1994); (8) refusing to testify falsely at a trial or administrative hearing, e.g., Sides, supra; and (9) refusing to violate a law, e.g., Adams, supra; D'Agostino v. Johnson & Johnson, Inc., 133 N.J. 516, 628 A.2d 305 (1993). Thus, many courts have recognized a more expansive exception to the rule of employment-at-will than this court did in Adams based on a broad public policy exception.

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