Sheets v. Teddy’s Frosted Foods

Brief Fact Summary.

The Plaintiff, Emard H. Sheets (Plaintiff) sued the Defendant, Teddy’s Frosted Foods (Defendant), for damages resulting from Defendant’s wrongful termination of Plaintiff.

Synopsis of Rule of Law.

When there is a state statute that includes a statement of public policy, the court should not ignore said policy when hearing wrongful termination actions.

Facts.

Defendant employed Plaintiff as quality control director and operations manager.  During his employment, Plaintiff noticed violations of the Connecticut Uniform Food, Drug and Cosmetic Act.  Plaintiff subsequently brought those violations to Defendant’s attention.  Defendant terminated Plaintiff for what it deemed unsatisfactory performance, but Plaintiff claimed that he was terminated in retaliation for his efforts to make sure Defendant complied with state labeling and licensing laws. 

Issue.

Is the termination of an employee for calling to the employer’s attention repeated violations of an act intended to “safeguard the public heath and promote the public welfare by protecting the consuming public from injury by product use and the purchasing public from injury by merchandising deceit” actionable?

Held.

Yes.  Judgment reversed and remanded for further proceedings. An employee at will may have an action for wrongful discharge if in the event he was required, as part of the job, to perform an illegal act and needed the job for his living purposes.

Dissent.

By allowing Plaintiff’s claim to proceed, the majority created a mechanism with which employees can coerce their employers to retain them.  The newly created cause of action was overly broad and its nuisance value may hinder an employer’s ability to make retention decisions regarding its employees.  Plaintiff could have anonymously communicated the violations to the commissioner of consumer affairs without jeopardizing his employment.  There was no evidence that Plaintiff did so during or after his employment. 

Concurrence.

Concurred without opinion.

Discussion.

Courts should not interfere with managerial discretion, but must ensure that employees are protected when their employer punishes them for their conduct as good citizens.  Employees must not be forced to weigh job security against protecting the public.