Haddle v. Garrison, 525 U.S. 121 (1998)

525 U.S. 121, 119 S. Ct. 489 (1998)

 

RULE:

The gist of the wrong at which 42 U.S.C.S. § 1985(2) is directed is not deprivation of property, but intimidation or retaliation against witnesses in federal-court proceedings. The terms "injured in his person or property" define the harm that the victim may suffer as a result of the conspiracy to intimidate or retaliate. Thus, the fact that employment at will is not "property" for purposes of the Due Process Clause, does not mean that loss of at-will employment may not injure a petitioner in his person or property for purposes of 42 U.S.C.S. § 1985(2)

FACTS:

Petitioner former employee alleged that respondents, former officers of employer, conspired to have him fired from his job in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at a federal criminal trial. Petitioner filed suit pursuant to 42 U.S.C.S. § 1985. Respondents brought a motion to dismiss for petitioner's alleged failure to state a claim upon which relief could be granted, which the appellate court granted. Petitioner then sought writ of certiorari review. The Supreme Court reversed and remanded the dismissal of petitioner former employee's claim holding that even though a person's employment contract was at will, he had a valuable contract right

ISSUE:

Was an employee "injured in his property or person" when his employer was induced to terminate the employee's at-will employment as part of a conspiracy prohibited by § 1985(2)?

ANSWER:

Yes.

CONCLUSION:

The sort of the harm alleged by petitioner , essentially third-party interference with at-will employment relationships, stated a claim for relief under 42 U.S.C.S. § 1985(2). Even though a person's employment contract was at will, he had a valuable contract right. The fact that employment at will is not "property" for purposes of the Due Process Clause, does not mean that loss of at-will employment may not "injure [petitioner] in his person or property" for § 1985(2)'s purposes. Such harm has long been, and remains, a compensable injury under tort law, and there is no reason to ignore this tradition here. To the extent that the terms "injured in his person or property" refer to such tort principles, there is ample support for the Court's holding.

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