Haddle v. Garrison

525 U.S. 121 (1998)

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Nature of the Case

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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).