Labor Law -- 1999



Haddle v. Garrison   (U.S. Supreme Court)

Employer liability for deterring employees from testifying in court

In this civil rights case, the Supreme Court ruled 12/14/98 that the loss of "at will" employment is a compensable injury under 42 U.S.C. § 1985(2), which provides a private cause of action for injuries arising from attempts to deter a witness from testifying in court. Haddle, a former at-will employee of a home health care company, claimed that Garrison and others had conspired to have him fired from his job to keep him from testifying as a witness in a Medicaid-fraud trial. The Eleventh Circuit, like the district court, held that the loss of at-will employment is not a compensable injury under § 1985(2) since an at-will employee has no constitutionally protected property interest in continued employment. The Supreme Court reversed and held that a constitutionally protected interest in continued employment is not a prerequisite to a claim for damages under § 1985(2).