Spero v. Lockwood, Inc.

BISTLINE, Justice,

dissenting.

The majority’s opinion does not apply Idaho law on this issue. Conspicuously absent is any substantive discussion of what contravenes this state’s public policy with respect to the discharge of an employee.

In MacNeil v. Minidoka Memorial Hospital, 108 Idaho 588, 589, 701 P.2d 208, 209 (1985), this Court last year held that an employee “hired pursuant to a contract which specifies the duration of the employment, or limits the reasons for which the employee may be discharged” is not an employee “at will.” Excluding those two situations, the current law in Idaho is that an employer can discharge an employee at will except “when the motivation for discharge contravenes public policy.” Id.1

In Jackson v. Minidoka Irrigation Dist., 98 Idaho 330, 333-34, 563 P.2d 54, 57-58 (1977), a unanimous Court set forth factors to consider in determining what constitutes “public policy”:

*76The employment at will rule is not ... an absolute bar to a claim of wrongful discharge. As a general exception to the rule allowing either the employer or the employee to terminate the employment relationship without cause, an employee may claim damages for wrongful discharge when the motivation for the firing contravenes public policy. The following cases illustrate this exception to the general rule.
In Petermann v. International Brotherhood of Teamsters, 174 Cal. App.2d 184, 344 P.2d 25 (1959), the court stated, “[generally, such a relationship is terminable at the will of either party (citations omitted) for any reason whatsoever (citations omitted). However, the right to discharge an employee under such a contract may be limited * * * by considerations of public policy.” The court continued, quoting from 72 C.J.S. Policy at page 212, to state, “public policy ‘is the principles under which freedom of contract or private dealing is restricted by law for the good of the community. Another statement, sometimes referred to as a definition, is that whatever contravenes good morals or any established interests of society is against public policy.’ ” In Petermann, the plaintiff/employee had been subpoenaed to testify before the California Legislature and was instructed by his employer to give false testimony. He was fired for answering truthfully. In reversing a judgment on the pleadings for the defendant, the court stated that coercing perjury is “patently contrary to the public welfare.”
In Frampton v. Central Indiana Gas Co., 260 Ind. 249, 297 N.E.2d 425 (1973), the plaintiff was fired for reporting an injury to her arm in order to file for workmen’s compensation. The court held that such an act was in clear contravention of public policy that the plaintiff had stated a claim upon which relief could be granted.
In Monge v. Beebe Rubber Co., 114 N.H. 130, 316 A.2d 549 (1974), the plaintiff claimed she was harassed by her foreman because she refused to go out with him and that his hostility, condoned if not shared, by the defendant/employer’s personnel manager, ultimately resulted in her being fired. The court said, “We hold that a termination by the employer of a contract of employment at will which is motivated by bad faith or malice or based on retaliation is not in the best interest of the economic system or the public good and constitutes a breach of the employment contract.”
In Nees v. Hocks, 272 Or. 210, 536 P.2d 512 (1975), the court concluded, “there can be circumstances in which an employer discharges an employee for such a socially undesirable motive that the employer must respond in damages for any injury done.” The court held that the plaintiff should be awarded compensatory damage for being fired because she served on jury duty against the wishes of her employer. (Emphasis added.)

In Idaho, the legislature has explicitly stated the public policy of this state as it relates to the discharge of an employee:

[T]he public policy of this state is declared to be as follows: Economic insecurity due to unemployment is a serious menace to the health, morals and welfare of the people of this state. Involuntary unemployment is therefore a subject of national and state interest and concern which requires appropriate action to prevent its spread and to lighten its burden which now so often falls with crushing force upon the unemployed worker and his family. The achievement of social security requires protection against this greatest hazard of our economic life. This can be provided by encouraging employers to provide more stable employment____ I.C. § 72-1302 (emphasis added).

In view of the legislature’s express declaration concerning involuntary unemployment, it is not readily seen how the discharge of an individual, which, in the words of the district judge, was “arbitrary and capricious,” can be viewed as anything but violative of public policy. If the public *77policy of this state — as expressed by our legislature — is to eradicate or minimize involuntary unemployment, then how is that policy not violated by the arbitrary and capricious acts of the employer here? The majority’s failure to address this issue does a disservice to the people of Idaho.

The cases relied upon in Minidoka Irrigation are being ignored; they teach that a firing done in bad faith or with malice, or which contravenes societal norms or established public interests, violates public policy. That is the exact situation we have here: the Idaho legislature has expressly stated that involuntary unemployment is against public policy; the district judge below found that Spero’s discharge was arbitrary and capricious — in other words an act of bad faith and malice. If this does not contravene the legislature’s express statement of this state’s public policy, one wonders what does? If Idaho’s public policy has not been violated here, the people of Idaho may well wonder whether that which Chief Justice Donaldson said last year in MacNeil, supra, is today considered to be of any substance. If it is, then we should be reversing the district court today. Accordingly, I dissent.

. The majority fails to acknowledge this exception. I do not view this silence to mean disapproval of the exception.