Haddle v. Garrison

Brief Fact Summary. Petitioner Michael A. Haddle, an at-will employee, alleges that respondents conspired to have him fired from his job in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at a federal criminal trial. 

Facts. Petitioner Michael A. Haddle, an at-will employee, alleges that respondents conspired to have him fired from his job in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at a federal criminal trial. 

Issue.  Whether such interference with at-will employment may give rise to a claim for damages under the Civil Rights Act of 1871, Rev. Stat §1980, 42 U.S.C. §1985 (2).

Held. That such interference with at-will employment may give rise to a claim for damages under the Civil Rights Act of 1871, Rev. Stat §1980, 42 U.S.C. §1985 (2).

Discussion.  In Morast v. Lance, 807 F.2d 926 (1987), the Eleventh Circuit held that an at-will employee who is dismissed pursuant to a conspiracy proscribed by §1985(2) has no cause of action, and must suffer an actual injury (no actual injury because the at-will employment was at-will).  This court disagreed with the Eleventh Circuit’s conclusion that petitioner must suffer an injury to a “constitutionally protected property interest” to state a claim for damages under §1985(2), and finds that the harm does give rise to a claim.