Civil Procedure I, Pages 381–383

Haddle v. Garrison (3)

Supreme Court of the United States, 1998

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Facts:

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.

Note:

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.

Rule:

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.

Reasoning:

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."

Rule/Holding:

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

Judgment:

Reversed and remanded.