HADDLE V. GARRISON 525 U.S. 121 (1998) CASE BRIEF

HADDLE V. GARRISON

525 U.S. 121 (1998)

NATURE OF THE CASE: This was a suit under Section 1985(2) of Title 42. Haddle (P), an at-will employee, filed this action for damages against respondents alleging, inter alia, that they conspired to have him fired in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at their upcoming criminal trial for Medicare fraud, and that their acts had 'injured [him] in his person or property' in violation of 42 U. S. C. 1985(2).

FACTS: Haddle (P) was a former employee of Healthmaster and claimed that he was improperly discharged in an attempt to deter his participation as a witness in a Federal Criminal Trial. P has conceded that he is an at will employee. P claimed that D's conspired with Molloy, one of the remaining officers of Healthmaster to get P fired as a result of his cooperation with federal agents. P stated two grounds for relief under 1985(2): one for conspiracy to deter him from testifying in the upcoming criminal trial and one for conspiracy to retaliate against him for attending the grand jury proceedings. As 1985 demands, he also alleged that he had been 'injured in his person or property' by the acts of respondents in violation of 1985(2) and that he was entitled to recover his damages occasioned by such injury against respondents jointly and severally. D moved under Rule 12(b)(6) to dismiss for a failure to state a claim upon which relief may be granted. Binding precedent interpreting 42 USC 1985 (2) requires that a plaintiff in this action must have incurred an injury and that an at will employee could not incur. This means an actual injury and here there was no constitutionally protected interest in continued employment. The court dismissed P's complaint for a failure to state a claim upon which relief may be granted; an at will employee cannot suffer an injury for a firing even for a wrongful purpose. In dismissing the suit for failure to state a claim, the District Court relied on Circuit precedent holding that an at-will employee discharged pursuant to a conspiracy proscribed by 1985(2) has suffered no actual injury because he has no constitutionally protected interest in continued employment. The Eleventh Circuit affirmed. The Eleventh Circuit's rule in Morast conflicts with the holdings of the First and Ninth Circuits. See Irizarry v. Quiros , 722 F. 2d 868, 871 (CA1 1983), and Portman v. County of Santa Clara , 995 F. 2d 898, 909-910 (CA9 1993).

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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