Thigpen v. Greenpeace, Inc., 93-CV-1321.
| Docket Nº | No. 93-CV-1321. |
| Citation | 657 A.2d 770 |
| Case Date | May 01, 1995 |
| Court | Court of Appeals of Columbia District |
657 A.2d 770
Bobby Charles THIGPEN, Appellant,
v.
GREENPEACE, INC., Appellee.
No. 93-CV-1321.
District of Columbia Court of Appeals.
Argued January 25, 1995.
Decided May 1, 1995.
H. Vincent McKnight, Jr., Washington, DC, for appellant.
Douglas C. Herbert, with whom Carol M. Booker, Washington, DC, was on the brief, for appellee.
Alan Banov, with whom Woodley B. Osborne, Washington, DC, was on the brief, for amicus curiae, Metropolitan Washington Employment Lawyers Ass'n.
Before STEADMAN, FARRELL and RUIZ, Associate Judges.
STEADMAN, Associate Judge:
Before us is an appeal by a discharged employee seeking to invoke the "very narrow exception" to the at-will doctrine articulated in Adams v. George W. Cochran & Co., Inc., 597 A.2d 28, 34 (D.C.1991). In his complaint, Bobby Charles Thigpen, a payroll clerk for appellee Greenpeace, alleged that in April of 1992, he discovered that Greenpeace was in violation of the District's minimum wage law, D.C.Code §§ 36-220 et seq. (1993). He notified two of his superiors of his belief. When no action was taken, he filed a complaint with the District's Wage and Hour Office. In July 1992, he was discharged by Greenpeace assertedly due to downsizing but in fact, the complaint alleged, for refusing to violate the laws of the District of Columbia. The trial
It has long been settled in the District of Columbia that an employer may discharge an at-will employee at any time and for any reason, or for no reason at all. Adams, 597 A.2d at 30. However, in Adams, for the first time, we held:
There is a very narrow exception to the at-will doctrine under which a discharged at-will employee may sue his or her former employer for wrongful discharge when the sole reason for the discharge is the employee's refusal to violate the law, as expressed in a statute or municipal regulation.
In Adams, the employee, a delivery truck driver, had refused to drive a truck that did not have an inspection sticker on its windshield. A municipal regulation prohibited the operation of a vehicle without a valid inspection sticker. We adopted what we termed the Texas rule, found in Sabine Pilot Service v. Hauck, 687 S.W.2d 733 (Tex.1985), which permits a fired at-will employee to sue only if the firing was "for the sole reason that the employee refused to perform an illegal act." 687 S.W.2d at 735. We concluded that it was "unacceptable and unlawful for his employer to compel him to choose between breaking the law and keeping his job." 597 A.2d at 34.
Thigpen here acknowledges that other than communicating with his superiors and filing the complaint with the District authorities, he continued to...
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Carl v. Children's Hosp., 93-CV-1476.
...or for no reason at all." Adams v. George W. Cochran & Co., supra, 597 A.2d at 30 (citing cases);1 see, e.g., Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995); Taylor v. Greenway Restaurant, Inc., 173 A.2d 211, 211 (D.C.Mun.1961); Pfeffer v. Ernst, 82 A.2d 763, 764 (D.C.Mun.1951). ......
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Riggs v. Home Builders Institute, 01CV0412.
...of D.C. minimum wage laws, notified two superiors of violations, filed a complaint after no action was taken, and was discharged. 657 A.2d 770, 771 (D.C.1995). The court explained that the Adams "exception requires an outright refusal to violate a specific law, with the employer putting the......
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Washington v. Guest Services, Inc., 96-CV-997.
...(D.C.), vacated, id. at 1102, opinion reinstated on denial of rehearing en banc, 609 A.2d 1143 (D.C.1992); Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995). But Thigpen was decided after Ms. Washington was discharged, and Guest Services could not have relied on it. The problems inh......
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Sokos v. Hilton Hotels Corp., Civil Action No. 01-963(RBW).
...law, with the employer putting the employee to the choice of breaking the law or losing his job." See Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995). Accordingly, the District of Columbia Court of Appeals has recognized only a limited number of public policy exceptions. See, e.g.......
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Carl v. Children's Hosp., 93-CV-1476.
...or for no reason at all." Adams v. George W. Cochran & Co., supra, 597 A.2d at 30 (citing cases);1 see, e.g., Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995); Taylor v. Greenway Restaurant, Inc., 173 A.2d 211, 211 (D.C.Mun.1961); Pfeffer v. Ernst, 82 A.2d 763, 764 (D.C.Mun.1951). ......
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Riggs v. Home Builders Institute, 01CV0412.
...of D.C. minimum wage laws, notified two superiors of violations, filed a complaint after no action was taken, and was discharged. 657 A.2d 770, 771 (D.C.1995). The court explained that the Adams "exception requires an outright refusal to violate a specific law, with the employer putting the......
-
Washington v. Guest Services, Inc., 96-CV-997.
...(D.C.), vacated, id. at 1102, opinion reinstated on denial of rehearing en banc, 609 A.2d 1143 (D.C.1992); Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995). But Thigpen was decided after Ms. Washington was discharged, and Guest Services could not have relied on it. The problems inh......
-
Sokos v. Hilton Hotels Corp., Civil Action No. 01-963(RBW).
...law, with the employer putting the employee to the choice of breaking the law or losing his job." See Thigpen v. Greenpeace, Inc., 657 A.2d 770, 771 (D.C.1995). Accordingly, the District of Columbia Court of Appeals has recognized only a limited number of public policy exceptions. See, e.g.......