Haddle v. Garrison Case Brief
Summary of Haddle v. Garrison
119 U S 489 
Relevant Facts: Pl, Haddle while employed with Healthmaster was called upon as a witness against his employers in a Federal action for fraud. Pl cooperated w/ the Federal agents and testified under subpoena before a grand jury. When the remaining partners learned of his impending testimony before a criminal proceeding they terminated him. Pl concedes that he was at all times an at-will employee.
Legal Issue(s): Whether the Petitioner was injured in his property or person when Respondents induced his employer to terminate petitioner’s at will employment as part of a conspiracy?
Court’s Holding: No
Procedure: Pl filed under 42 USC 1985 Civil Rights Act and other state claims, Dfs filed four separate motions to dismiss under Rule 12 (b) (6). D. Ct granted and Dismissed. Ct of App affirmed under Morast v Lance 807 F 2d 926; S Ct Reversed and remanded.
Law or Rule(s): One who maliciously and w/o justifiable cause, induces an employer to discharge an employee, by means of false statements, threats or putting in fear, is liable in an action of tort to the employee, and it makes no difference whether the employment was for a fixed term not yet expired or is terminable at the will of the employer.
Court Rationale: A ct should not dismiss a complaint for failure to state a claim unless it is clear that the Pl can prove “no set of facts in support of his claim which would entitle him to relief.” To make out a cause of action the Pl must have suffered an actual injury. We disagree w/ the Ct of App that b/c the Pl was an at will employee he has no constitutionally protected interest in continued employment. The wrong at which 1985 (2) is directed is not deprivation of property, but intimidation or retaliation against witnesses in federal court proceedings. The sort of harm alleged by the Petitioner here -third party interference w/ at will employment relationships – states a claim for relief under 1985 (2). Such harm has long been a compensable injury under tort law.
Plaintiff’s Argument: Pl can maintain an action under 42 USC 1985 even if he was an at will employee b/c the respondents induced his termination as part of a conspiracy.
Defendant’s Argument: As an at will employee, Pl, could not have suffered an injury when discharges, Df was free to discharge without cause, as well as the Pl was free to remove himself without cause or notice.