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Wright v. Shriners Hosp. for Crippled Children - 412 Mass. 469, 589 N.E.2d 1241 (1992)

Rule:

Employment at will is terminable by either the employee or the employer without notice, for almost any reason or for no reason at all. The courts recognize exceptions to that general rule, however, when employment is terminated contrary to a well-defined public policy. Thus, redress is available for employees who are terminated for asserting a legally guaranteed right such as filing a workers' compensation claim, for doing what the law requires such as serving on a jury, or for refusing to do that which the law forbids such as committing perjury. Redress is also available to an at-will employee who is discharged in retaliation for his cooperation with a law enforcement investigation concerning his employer.

Facts:

Shriners Hospital for Crippled Children (Shriners Hospital) hired plaintiff Anita Wright, a registered nurse, in 1976. Subsequently, she became assistant director of nursing, and she held that position until she was discharged in late February of 1987. At all times, she was an employee at will. Wright received excellent evaluations throughout her employment, including an evaluation in December, 1986, two months before her discharge. Wright was discharged as a result of unfavorable comments she made during two separate surveys that were conducted by the hospital's national headquarters. Subsequently, Wright instituted suit against the Hospital, alleging that Shriners Hospital wrongfully terminated her at-will employment in violation of public policy. The trial court entered judgment in favor of Wright; thereafter, Shriners Hospital appealed.

Issue:

Did Shriners Hospital wrongfully terminate Anita Wright’s at-will employment, in violation of public policy?

Answer:

No.

Conclusion:

The Court held that the action of Shriners Hospital in terminating the at-will employment of Anita Wright would not, as matter of law, have violated public policy, even if the termination were shown to have been in reprisal for Wright’s criticism of the hospital during interviews with members of a survey team representing the national organization to which the hospital belonged. According to the Court, employment at-will was terminable by either party without notice, for almost any reason or for no reason at all; as such, the Court rejected Wright’s argument that her termination was against public policy because although statutes required notification of abuse, the nurse testified that she did not consider the patient care that caused her concern to be abuse, neglect, or mistreatment, nor did she believe that there was an issue of physician incompetence. The Court noted that the nurse's report was an internal matter and internal matters could not have been the basis of a public policy exception to the at-will rule.

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