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Law School Case Brief

Sheets v. Teddy's Frosted Foods, Inc. - 179 Conn. 471, 427 A.2d 385 (1980)


A cause of action is stated when an employee alleges that he was discharged in retaliation for his refusal to manipulate and alter sampling results for pollution control reports required by Michigan law. Falsified reports violate state law. In another case, an employee states a cause of action when he alleges that he was discharged in retaliation for his efforts to ensure his employer's compliance with state and federal consumer credit protection laws. The legislature has established a public policy of consumer protection. In another case, the plaintiff is entitled to a trial to determine whether she was wrongfully discharged for refusing to pursue clinical testing of a new drug containing a high level of saccharin; the court notes that the plaintiff's status as a physician entitles her to invoke the Hippocratic Oath as well as state statutory provisions governing the licensing and the conduct of physicians.


Plaintiff had worked as a quality control director and operations manager for the employer for four years. He began to notice deviations from the specifications contained the employer's standards and labels, which violated the provisions of the Connecticut Uniform Food, Drug, and Cosmetic Act (Act), Conn. Gen. Stat. § 19-222. He communicated in writing to the employer regarding the deviations and he was discharged a few months later. Plaintiff employee filed a complaint for wrongful discharge. The court ruled in favor of the defendant employer.


Did the court err in granting defendant’s motion to strike the complaint for being legally insufficient?




The court found that although the stated reason for his discharge was unsatisfactory performance, plaintiff was actually dismissed in retaliation for his efforts to ensure that the employer's products complied with applicable law. The plaintiff alleged that he had been dismissed in retaliation for his insistence that the defendant comply with the requirements of a state statute, the Food, Drug and Cosmetic Act. The court noted that certainly when there is a relevant state statute we should not ignore the statement of public policy that it represents.

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