Wrongful Termination in Pennsylvania

Background

“An at-will employment relationship may be terminated by either the employer or the employee at any time, for any reason or for no reason at all.” (See Haines v. St. Luke's Hosp., 2148 EDA 2020, at *3 (Pa. Super. Ct. Sep. 13, 2021).)

“Therefore, as a general rule, an at-will employee has no cause of action for wrongful discharge against her employer.” (See id.)

“A limited exception to this rule exists that permits an at-will employee to bring an action for wrongful discharge where the termination of employment violates a clear mandate of Pennsylvania public policy.” (See id.)

General Information for Complaints and Motions

“This public policy exception applies and permits a cause of action for wrongful discharge where the employer discharges an employee for refusing to commit a crime, where the employer discharges an employee for complying with a statutorily imposed duty, or where the employer is specifically prohibited by statute from discharging the employee.” (See Haines v. St. Luke's Hosp., 2148 EDA 2020, at *4 (Pa. Super. Ct. Sep. 13, 2021).)

“Termination of employment in retaliation for exercise of an employee's rights to workers' compensation benefits or unemployment compensation can also constitute a violation of public policy that supports a wrongful discharge cause of action.” (See id.)

“Outside of those narrow types of circumstances, claims that a discharge falls within the public policy exception have been repeatedly rejected, even where the plaintiff has alleged that she was unfairly treated.” (See id.)

Standard of Review and Burdens of Proof

“The scope of this Court's review of a grant or denial of summary judgment is limited to determining whether the trial court committed an error of law or an abuse of discretion.” (See Kaplan v. Se. Pa. Transp. Auth. (1997) 688 A.2d 736, 738 n. 2; Quinones v. Commonwealth (2012) 45 A.3d 467, 469 n.1.)

“Summary judgment is appropriate only when, after examining the record in the light most favorable to the non-moving party, there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.” (See Guy M. Cooper, Inc. v. E. Penn Sch. Dist. (2006) 903 A.2d 608, 613; Quinones v. Commonwealth (2012) 45 A.3d 467, 469 n.1.)

“The appellate standard of review is de novo when a reviewing court considers questions of law.” (See Weaver v. Lancaster Newspapers, Inc. (2007) 592 Pa. 458, 926 A.2d 899; Quinones v. Commonwealth (2012) 45 A.3d 467, 469 n.1.)

“In reviewing questions of law, the scope of review is plenary, as the reviewing court may examine the entire contents of the record.” (See id.)

The Court’s Decisions

It is well settled that “if a violation of a clear mandate of public policy results in the termination of an at-will employee, that employee would have a right of action for wrongful discharge.” (See Rothrock v. Rothrock Motor Sales, Inc. (2005) 584 Pa. 297, 304.)

It is also well settled that “Pennsylvania's traditional view [is] that exceptions to at-will termination should be few and carefully sculpted so as to not erode an employer's inherent right to operate its business as it chooses.” (See id.)