at-will employment doctrine in Connecticut

2021In creating this public policy exception to the at-will employment doctrine, the court in Sheets stated that an employee may have a cause of action when the employee alleges ‘‘a demon- strably improper reason for dismissal, a reason whose impropriety is derived from some important violation of public policy.’’ (Emphasis omitted.) Id., 475 . ‘‘Although the court in Sheets recognized a public policy limitation on [this] doctrine in an effort to bal- ance the competing interests of employers and employ- ees . . . [it also] recognized the inherent vagueness of the concept of public policy and the

2021However, in Sheets v. Teddy’s Frosted Foods, Inc., 179 Conn. 471, 475 , 427 A.2d 385 (1980), our Supreme Court recognized an exception to the at-will employment doctrine: a com- mon-law cause of action for wrongful discharge exists ‘‘if the former employee can prove a demonstrably improper reason for dismissal, a reason whose impro- priety is derived from some important violation of pub- lic policy.’’ (Emphasis omitted.) Id.

2012Cf. Morris v. Hartford Courant Co., 200 Conn. 676, 679-80 , 513 A.2d 66 (1986) (false but negligent accusation of criminal conduct as basis for dismissal not demonstrably improper reason for discharge where employer had no statutory duty to investigate).

2012Cf. Morris v. Hartford Courant Co., 200 Conn. 676, 679-80 , 513 A.2d 66 (1986) (false but negligent accusation of criminal conduct as basis for dismissal not demonstrably improper reason for discharge where employer had no statutory duty to investigate).

2006The public policy exception to the at-will employment doctrine, however, is “to be construed narrowly.” Fenner v. Hartford Courant Co., 77 Conn. App. 185, 194 , 822 A.2d 982 (2003).

2006The public policy exception to the at-will employment doctrine, however, is “to be construed narrowly.” Fenner v. Hartford Courant Co., 77 Conn. App. 185, 194 , 822 A.2d 982 (2003).

2002In refusing to recognize the plaintiffs common-law cause of action, the majority relies in part on Burnham v. Karl & Gelb, P.C., 252 Conn. 153 , 745 A.2d 178 (2000).

2002In refusing to recognize the plaintiffs common-law cause of action, the majority relies in part on Burnham v. Karl & Gelb, P.C., 252 Conn. 153 , 745 A.2d 178 (2000).

2021The purpose of the at-will employment doctrine is to ‘‘preserve the autonomy of managerial discretion in the work place and the freedom of the parties to make their own contract.’’ Magnan v. Anaconda Industries, Inc., 193 Conn. 558, 563 , 479 A.2d 781 (1984).

2021The purpose of the at-will employment doctrine is to ‘‘preserve the autonomy of managerial discretion in the work place and the freedom of the parties to make their own contract.’’ Magnan v. Anaconda Industries, Inc., 193 Conn. 558, 563 , 479 A.2d 781 (1984).

2021See, e.g., Thibodeau v. Design Group One Architects, LLC, supra, 260 Conn. 700–701; Parsons v. United Technologies Corp., 243 Conn. 66, 79 , 700 A.2d 655 (1997).

2021See, e.g., Thibodeau v. Design Group One Architects, LLC, supra, 260 Conn. 700–701; Parsons v. United Technologies Corp., 243 Conn. 66, 79 , 700 A.2d 655 (1997).

2016Moreover, although this court has the discretion to address an abandoned claim; Ward v. Greene, 267 Conn. 539 , 546, 839 A.2d 1259 (2004) ; we should be particularly cautious of addressing a claim that, in essence, asks the court to recognize a new and broad public policy exception to the at-will employment doctrine without adequate briefing because of the narrowness of the public policy exception to the at-will employment doctrine.

2016Moreover, although this court has the discretion to address an abandoned claim; Ward v. Greene, 267 Conn. 539 , 546, 839 A.2d 1259 (2004) ; we should be particularly cautious of addressing a claim that, in essence, asks the court to recognize a new and broad public policy exception to the at-will employment doctrine without adequate briefing because of the narrowness of the public policy exception to the at-will employment doctrine.

2002For example, in Antinerella v. Rioux, supra, 229 Conn. 479 , we held that the plaintiff, a deputy sheriff, had stated a claim for wrongful termination against the defendant, the high sheriff of Hartford county; id., 493-94 ; predicated upon the deputy sheriffs allegation that the high sheriff had discharged him “in order to take [over] his [process serving] business and personally benefit under [a] statutorily forbidden and illegal fee splitting arrangement he had made with several appointed deputy sheriffs.” 11 Id., 491 .

2001Similarly, in both Green v. Ralee Engineering Co., 19 Cal. 4th 66 , 960 P.2d 1046 , 78 Cal. Rptr. 2d 16 (1998), and Stevenson v. Superior Court, 16 Cal. 4th 880 , 941 P.2d 1157 , 66 Cal. Rptr. 2d 888 (1997), the Supreme Court of California reviewed the relevant case law concerning exceptions to the at-will employment doctrine in California.

2001Similarly, in both Green v. Ralee Engineering Co., 19 Cal. 4th 66 , 960 P.2d 1046 , 78 Cal. Rptr. 2d 16 (1998), and Stevenson v. Superior Court, 16 Cal. 4th 880 , 941 P.2d 1157 , 66 Cal. Rptr. 2d 888 (1997), the Supreme Court of California reviewed the relevant case law concerning exceptions to the at-will employment doctrine in California.

2001Similarly, in both Green v. Ralee Engineering Co., 19 Cal. 4th 66 , 960 P.2d 1046 , 78 Cal. Rptr. 2d 16 (1998), and Stevenson v. Superior Court, 16 Cal. 4th 880 , 941 P.2d 1157 , 66 Cal. Rptr. 2d 888 (1997), the Supreme Court of California reviewed the relevant case law concerning exceptions to the at-will employment doctrine in California.

2001Similarly, in both Green v. Ralee Engineering Co., 19 Cal. 4th 66 , 960 P.2d 1046 , 78 Cal. Rptr. 2d 16 (1998), and Stevenson v. Superior Court, 16 Cal. 4th 880 , 941 P.2d 1157 , 66 Cal. Rptr. 2d 888 (1997), the Supreme Court of California reviewed the relevant case law concerning exceptions to the at-will employment doctrine in California.

2000In Sheets v. Teddy’s Frosted Food, Inc., 179 Conn. 471, 475 , 427 A.2d 385 (1980), we recognized a common-law cause of action in tort for the discharge of an at-will employee “if the former employee can prove a demonstrably improper reason for dismissal, a reason whose impropriety is derived from some important violation of public policy.” More recently, this court concluded that “claims brought pursuant to the public policy limitation on the at-will employment doctrine can be predicated on the violation of public policy expressed in a federal statute.” Faulkner v. United Technologies Corp., 2

2000In Sheets v. Teddy’s Frosted Food, Inc., 179 Conn. 471, 475 , 427 A.2d 385 (1980), we recognized a common-law cause of action in tort for the discharge of an at-will employee “if the former employee can prove a demonstrably improper reason for dismissal, a reason whose impropriety is derived from some important violation of public policy.” More recently, this court concluded that “claims brought pursuant to the public policy limitation on the at-will employment doctrine can be predicated on the violation of public policy expressed in a federal statute.” Faulkner v. United Technologies Corp., 2

1997The defendant cites the following cases in support of this proposition: McKenzie v. Renberg’s, Inc., 94 F.3d 1478, 1487-88 (10th Cir. 1996) (interpreting Oklahoma law to require plaintiffs claiming wrongful discharge to cite violations of Oklahoma statutes, constitutional provisions, or judicial decisions); Hicks v. Resolution Trust Corp., 970 F.2d 378, 380-81 (7th Cir. 1992) (interpreting Illinois law to require plaintiffs claiming wrongful discharge in violation of public policy expressed in federal statute to articulate clearly mandated state public policy); Olguin v. Inspiration Consolidat

1980Super. 335 , 399 A.2d 1023 , the court, upon declaring that there should be a trial to determine whether the plaintiff’s alleged retaliatory discharge was in fact and in law wrongful, stated (p. 1026), inter alia: “[I]f there is to be such an exception to the at-will employment rule, it must be tightly circumscribed so as to apply only in cases involving truly significant matters of clear and well-defined public policy and substantial violations thereof. . . . [T]he adoption of any such new doctrine must be grounded in a specific factual and legal context resulting from a plenary hearing, at w

1980Super. 335 , 399 A.2d 1023 , the court, upon declaring that there should be a trial to determine whether the plaintiff's alleged retaliatory discharge was in fact and in law wrongful, stated (p. 1026), inter alia: "[I]f there is to be such an exception to the at-will employment rule, it must be tightly circumscribed so as to apply only in cases involving truly significant matters of clear and well-defined public policy and substantial violations thereof.... [T]he adoption of any such new doctrine must be grounded in a specific factual and legal context resulting from a plenary hearing, at whic