Haddle v. Garrison

PETITIONER: Haddle
RESPONDENT: Garrison
LOCATION: Alden's Workplace

DOCKET NO.: 97-1472
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eleventh Circuit

CITATION: 525 US 121 (1998)
ARGUED: Nov 10, 1998
DECIDED: Dec 14, 1998

ADVOCATES:
Charles C. Stebbins - Argued the cause for the petitioner
Matthew D. Roberts - Department of Justice, for the United States, as amicus curiae, supporting the petitioner
Phillip A. Bradley - Argued the cause for the respondents

Facts of the case

Michael A. Haddle, an at-will employee for Healthmaster, Inc., filed suit in federal court alleging his employer, along with 2 previous Healthmaster, Inc. officers, Jeanette Garrison and Dennis Kelly, conspired to have him fired in retaliation for obeying a federal grand jury subpoena and later testifying in a criminal trial against Healthmaster, Inc. for Medicare fraud. Haddle claimed his employers' acts had had "injured [him] in his person or property" in violation of federal law, specifically the Civil Rights Act of 1871. The District Court, relying on precedent, dismissed the suit for failure to state a claim. The precedent the court cited held that an at-will employee discharged pursuant to a conspiracy proscribed by the Act has suffered no actual injury because he has no constitutionally protected interest in continued employment. The Court of Appeals affirmed.

Question

May at-will employees sue their employers over firings allegedly carried out to retaliate for testimony against their employers?

Media for Haddle v. Garrison

Audio Transcription for Oral Argument - November 10, 1998 in Haddle v. Garrison

Why do you assume that?

We're not talking about deprivation of constitutionally protected property.

If... if, for example, at-will employment was not considered or any interference with at-will employment was not considered to be a tort at the time this provision was adopted, why... why would I believe that the Congress which enacted this would want that rather minor injury to be sucked into the provision because some future states give causes of action for interference with at-will employment?

Phillip A. Bradley:

You have to distinguish between constitutionally protected rights, the privileges and immunities of citizenship, which are different than property which is simply protected by procedural due process.

Charles C. Stebbins:

--Well, Your Honor, I have two answers to that.

Phillip A. Bradley:

And the... the Court's rulings are uniform, that to define property for procedural due process purposes, you look outside the Constitution to such places as State law.

Charles C. Stebbins:

First of all, the most direct answer would be that when Congress legislates in this broad manner and says, injured in his person or property, I believe Congress expects and it necessarily follows that this Court and the lower courts, the courts below, are going to develop a law to interpret these broad terms, and that law is going to change over time, just as in the antitrust laws which is the closest analogy in terms of the actual words used where there's a reference to injured in business or property.

Mr.--

Charles C. Stebbins:

This Court is then faced with the... and the lower courts are faced with the necessity of developing the law as cases appear before it, and that's a necessary concomitant of a common law system.

Phillip A. Bradley:

This Court has never held at-will employment to be property in that context.

Charles C. Stebbins:

But I'd also like to say more specifically I understand the... the... Justice Scalia, what you said about it matters to you all, but not to us, but I do want not to lose sight of the fact that there is no evidence at all that this injury was not compensable at common law at the time or that it would not be compensable under the State law of the State of Georgia to somebody.

--You're right.

Charles C. Stebbins:

Now, I'd like to reserve any further time I have, Mr. Chief Justice, if there are no further questions.

I--

Very well, Mr. Stebbins.

--Mr. Bradley, I think we are less concerned... or at least I am.

Mr. Roberts, we'll hear from you.

I'm... I'm not sure we have before us the question of what property means.

Matthew D. Roberts:

Mr. Chief Justice, and may it please the Court:

I think what we have before us more precisely is what the phrase injury to person or property means, and... and what other... what other statutes use precisely that phrase and have been interpreted in a way favorable to you?

Matthew D. Roberts:

Petitioner was injured in his person or property because he lost wages when he was fired pursuant to a conspiracy prohibited by section 1985.

I mean, property in isolation is something different, but somehow the phrase injury to person or property means all sorts of injury, whatever injury, whether it's, you know... that's the argument made by the petitioner here, and I... and I think there's something to it.

Matthew D. Roberts:

Subsection 2 of section 1985 protects the Federal courts by creating a Federal right to be free of conspiracies to interfere with Federal witnesses--

Do you have other statutes that use precisely that phrase, injury to person or property?

Well, should we look to State law to determine whether there's injury to person or property?

Phillip A. Bradley:

There are not many statutes that use that precise phrase, injury to person or property.

Matthew D. Roberts:

--No, Your Honor.

Phillip A. Bradley:

I would like to take you, if I may, Justice Scalia, to this particular statute and look at some of the scenarios that arise if you construe injury to person or property in this particular context to mean what the petitioner and the Government--

Why not?

Before you do that, could you just clarify the answer to my... to what I had asked?