Civil Procedure I, Pages 381–383

Haddle v. Garrison (3)

Supreme Court of the United States, 1998


Plaintiff was a former at-will employee of defendant's, and claimed to be improperly discharged for obeying a federal subpoena to deter him from testifying. The trial was a federal criminal trial against defendant, in which plaintiff was expected to testify against defendant. Defendant filed a 12(b)(6) motion for failure to state a complaint.

Procedural History:

District Court granted defendant's 12(b)(6) motion and dismissed without prejudice. Court of Appeals affirmed based on Morast v. Lance.


Morast said that no cause of action could be had under §1985(2) because at-will employment was not a constitutionally protected interest and therefore did not constitute an injury.


Page 382, Paragraph 3, Bottom

Can petitioner state a claim for damages by alleging that a conspiracy proscribed by §1985(2) induced his employer to terminate his at-will employment.


Nothing in §1985(2) says the injury must be to a constitutionally protected property interest. The intention is not concerning deprivation of property but about intimidation of witnesses. It does not matter that employment at will is not "property."


Third-party interference with at-will employment relationships states a claim for relief under §1985(2).


Reversed and remanded.

See Also:

  • Haddle v. Garrison (1)
  • Haddle v. Garrison (2)