Bochnowski v. Peoples Federal Savings & Loan Ass'n

RATLIFF, Chief Judge,

dissenting.

I respectfully dissent. The rule of law found in Stanley v. Kelley (1981), Ind.App., 422 N.E.2d 663, which provides that a defendant may induce the discharge of an at-will employee and not be subject to a suit for the tortious interference with an employment relationship absent illegal action, imposes a minority position that is unjust and unreasonable for two reasons. First, this rule is based upon the mistaken conclusion that since the employee has no enforceable rights against the employer’s decision to discharge, he likewise has no cause of action against the interferer absent illegal action. A majority of jurisdictions have rejected this faulty reasoning and broad conclusion. Truax v. Raich (1915), 239 U.S. 33, 36 S.Ct. 7, 60 L.Ed. 131; American Surety Co. v. Schottenbauer (8th Cir.1958), 257 F.2d 6 (applying Minnesota law); Evans v. Swaim (1944), 245 Ala. 641, 18 So.2d 400; Hill Grocery Co. v. Carroll (1931), 223 Ala. 376, 136 So. 789; Mason v. Funderburk (1969), 247 Ark. 521, 446 S.W.2d 543; Kozlowsky v. Westminster National Bank (1970), 6 Cal.App.3d 593, 86 Cal.Rptr. 52; Gibson v. Fidelity and Casualty Co. (1907), 232 Ill. 49, 83 N.E. 539; London Guarantee and Accident Co. v. Horn (1903), 206 Ill. 493, 69 N.E. 526; Hilton v. Sheridan Coal Co. (1931), 132 Kan. 525, 297 P. 413. In rejecting the conclusion reached in Stanley, the United States Supreme Court reasoned in Truax, as follows:

“The right to earn a livelihood and to continue in employment unmolested by efforts to enforce void enactments should similarly be entitled to protection in the absence of adequate remedy at law. -It is said that the bill does not show an employment for a term, and that under an employment at will the complainant could be discharged at any time, for any reason or for no reason, the motive of the employer being immaterial. The conclusion, however, that is sought to be drawn, is too broad. The fact that the employment is at the will of the parties, respectively, does not make it one at the will of others. The employee has manifest interest in the freedom of the employer to exercise his judgment without illegal interference or compulsion and, by the weight of authority, the unjustified interference of third persons is actionable although the employment is at will.”

Truax, 239 U.S. at 38, 36 S.Ct. at 9, 60 L.Ed. at 134 (citations omitted). I agree with the reasoning adopted by the majority of jurisdictions. Thus while Bochnowski’s at-will status should preclude him from recovering damages in a suit against his employer for being discharged, his at-will status should not preclude a suit against Peoples Federal. Therefore, I believe the reasoning in Stanley which precludes a suit against Peoples Federal based upon Bo-*128chnowski’s at-will status should be rejected and the rule preventing recovery should be changed.

The second reason that the rule in Stanley should be changed is that this rule enables and entitles a defendant/interferer to induce the termination of an at-will employee without a legitimate business justification. Such influencing ability has been held to be inequitable and improper. Prosser, Law of Torts § 129 p. 946 (4th ed. 1971); Annot., 79 A.L.R. 672 (1977). While a defendant may not be held liable for inducing the termination of an at-will employee if a legitimate business justification exists, “when there is no competitive relation, but the object is to put pressure upon the plaintiff and coerce him into complying with the defendant's wishes in some collateral matter — as where an employer is induced to discharge a workman in order to compel him to pay the defendant a debt, prevent him from bringing a suit, or force him to compromise a claim, or for the purpose of extorting money from him,” then a defendant may be held liable for the resultant damage to the employee. Prosser, at 746 (footnote omitted). Thus, a defendant should not be allowed to interfere to secure an unrelated advantage against an at-will employee. Id. A majority of jurisdictions agree and hold that an at-will employee may bring suit and recover damages from a defendant who induces the termination of the at-will employee without justification. Prosser, pp. 932-33; Truax, supra; Schottenbauer, supra; Evans, supra; Wagenseller v. Scottsdale Memorial Hospital (1985), 147 Ariz. 370, 710 P.2d 1025; Mason, supra; Kozlowsky, supra; American Standard, Inc. v. Jessee (1979), 150 Ga. App. 663, 258 S.E.2d 240; Gibson, supra; Horn, supra; Hilton, supra; Pino v. Trans-Atlantic Marine, Inc. (1970), 358 Mass. 498, 265 N.E.2d 583; Smith v. Ford Motor Co. (1976), 289 N.C. 71, 221 S.E.2d 282, 79 A.L.R.3d 651; Sides v. Duke Hospital (1985), 74 N.C.App. 331, 328 S.E.2d 818; Mansour v. Abrams (1986), 120 A.D.2d 933, 502 N.Y.S.2d 877; Smith v. Klein (1985), 23 Ohio App.3d 146, 492 N.E.2d 852; Del State Bank v. Salmon (1976), Okla., 548 P.2d 1024; Lewis v. Oregon Beauty Supply Co. (1987), 302 Or. 616, 733 P.2d 430; Ladd v. Roane Hosiery, Inc. (1977), Tn., 556 S.W.2d 758; Bachand v. Connecticut General Life Ins. Co. (1981), 101 Wis. 2d 617, 305 N.W.2d 149.

The foregoing authorities clearly enunciate the better rule with regard to the interference with an at-will employment relationship. Accordingly, I believe the rule in Stanley should be overturned and modified, and if Peoples Federal induced the termination of Bochnowski without a legitimate business justification, Bochnowski should be entitled to recover damages. The evidence in the present case conflicts as to whether Bochnowski was terminated based upon an inducement by Peoples Federal and as to whether Peoples Federal’s alleged inducement was supported by a legitimate business justification. Therefore, I would reverse the trial court’s grant of summary judgment and remand for trial.