Haddle v. Garrison

Brief Fact Summary. Plaintiff Michael A. Haddle appealed a District Court’s dismissal of his suit for failure to state a claim upon which relief could be granted under Federal Rule of Civil Procedure 12(b)(6).

Synopsis of Rule of Law. Appeals from FRCP 12(b) (6) motions are not reviewable where binding precedent renders the complaint without legal recourse.

Facts. Plaintiff had filed a 42 USC Section: 1985(2) claim against his former employer for allegedly firing him in an attempt to prevent him from testifying in a Federal criminal trial. Defendant Garrison, Plaintiff’s former employer, filed a motion to dismiss under 12(b) (6) on grounds that Plaintiff was entitled to no protection under Section: 1985(2) because he was an at-will employee. The District Court granted the motion, which Plaintiff then appealed.

Issue. Whether Plaintiff’s arguments on appeal were foreclosed by the 11th Circuit Court’s earlier decision in Morast v. Lance, 807 F.2d 926 (11th Cir. 1987).

Held. Yes. The Court issued a per curiam opinion affirming the decision of the district court.
Discussion. The Court concluded that because Plaintiff himself admitted in his pleadings that he was an at-will employee, that the binding case law holding at-will employees are not entitled to any Constitutional protections, prevented the Court’s consideration of whether the 12(b) (6) standard had been properly applied.