wrongful discharge claim (Maryland) · Go Syfert
← Maryland issues

wrongful discharge claim in Maryland

15 Maryland opinions name it 2 courts 1991–2017 0 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Makovi v. Sherwin-Williams Co.green
md · 1989 · cited in 3 Maryland opinions naming this issue, 2002–2004
2 sentences

2004Concerning appellant’s common law wrongful discharge claims (Counts III and VII), the court stated that “a wrongful discharge claim may not lie” because the “statutory remedies provided by Article 49B and *26 the ADEA preempt any common law wrongful discharge claim.” Citing Makovi v. Sherwin-Williams Co., 316 Md. 603 , 561 A.2d 179 (1989), and Insignia Residential Corp. v. Ashton, 359 Md. 560 , 755 A.2d 1080 (2000), the court added: “[I]f the legislature has provided the vehicle by which a plaintiff may remedy a specific employment wrongdoing as an exception to the terminable at-will rule, an

2004Concerning appellant’s common law wrongful discharge claims (Counts III and VII), the court stated that “a wrongful discharge claim may not lie” because the “statutory remedies provided by Article 49B and *26 the ADEA preempt any common law wrongful discharge claim.” Citing Makovi v. Sherwin-Williams Co., 316 Md. 603 , 561 A.2d 179 (1989), and Insignia Residential Corp. v. Ashton, 359 Md. 560 , 755 A.2d 1080 (2000), the court added: “[I]f the legislature has provided the vehicle by which a plaintiff may remedy a specific employment wrongdoing as an exception to the terminable at-will rule, an

23
Parks v. Alpharma, Inc.green
md · 2011 · cited in 2 Maryland opinions naming this issue, 2016–2017
2 sentences

2017Moreover, although accepting as a general matter that federal laws and regulations could form the basis for a wrongful termination claim in Maryland, the Parks Court determined that the Federal Trade Commission (FTC) and Federal Drug Administration (FDA) regulations lacked “the specificity of public policy that we have required to support a wrongful discharge claim.” Parks, 421 Md. at 83, 86 , 25 A.3d at *454 202-03, 215 (“The regulation at issue provides the FDA’s standard for what details must be included on a prescription drug label if there is ‘reasonable evidence’ that a particular drug h

2016Although accepting as a general matter that federal law and regulation could form the basis for the tort in Maryland, the Court found that Federal Trade Commission (FTC) and Federal Drug Administration (FDA) regulations lacked “the specificity of public policy that we have required to support a wrongful discharge claim.” 421 Md. at 83 , 25 A.3d 200 . 5 The Court noted the “extensiveness” of 15 U.S.C. § 45 (a)(2), which vested in the FTC the exclusive power to determine the unfairness of a business practice based on a consideration of its value versus its harm to consumers.

22
Thompson v. Memorial Hospital at Easton, Maryland, Inc.green
mdd · 1996 · cited in 2 Maryland opinions naming this issue, 2001–2002
2 sentences

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D.409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

22
Wholey v. Roebuckgreen
md · 2002 · cited in 4 Maryland opinions naming this issue, 2003–2017
2 sentences

2017See also Wholey, 370 Md. at 52-54 , 803 A.2d at 490-91 (“The first limiting factor with respect to adopting a ‘new* public policy mandate for a wrongful discharge claim is derived from the generally accepted purpose behind recognizing the tort in the first place: to provide a remedy for an otherwise unremedied violation of public policy....

2017See also Wholey, 370 Md. at 52-54 , 803 A.2d at 490-91 (“The first limiting factor with respect to adopting a ‘new* public policy mandate for a wrongful discharge claim is derived from the generally accepted purpose behind recognizing the tort in the first place: to provide a remedy for an otherwise unremedied violation of public policy....

14
Watson v. Peoples Security Life Insurancegreen
md · 1991 · cited in 3 Maryland opinions naming this issue, 2002–2005
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

13
Bleich v. Florence Crittenton Services of Baltimore, Inc.green
mdctspecapp · 1993 · cited in 2 Maryland opinions naming this issue, 2002–2005
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

12
Shapiro v. Massengillgreen
mdctspecapp · 1995 · cited in 2 Maryland opinions naming this issue, 2001–2002
2 sentences

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

12
Porterfield v. Mascari II, Inc.green
md · 2003 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

11
Chappell v. Southern Maryland Hospital, Inc.green
md · 1990 · cited in 1 Maryland opinions naming this issue, 2002–2002
2 sentences

2002See Chappell v. Southern Maryland Hosp., 320 Md. 483, 493 , 578 A.2d 766, 772 (1990)(flnding it unnecessary to apply a tort remedy where the employee had other civil remedies available under both state and federal law); Makovi v. Sherwin-Williams Co., 316 Md. 603, 626 , 561 A.2d 179, 190 (1989).

2002See Chappell v. Southern Maryland Hosp., 320 Md. 483, 493 , 578 A.2d 766, 772 (1990)(flnding it unnecessary to apply a tort remedy where the employee had other civil remedies available under both state and federal law); Makovi v. Sherwin-Williams Co., 316 Md. 603, 626 , 561 A.2d 179, 190 (1989).

11
Faust v. Ryder Commercial Leasing & Servicesgreen
moctapp · 1997 · cited in 1 Maryland opinions naming this issue, 2002–2002
2 sentences

2002To qualify for the public policy exception to at-will employment, the employee must report the suspected criminal activity to the appropriate law enforcement or judicial official,' not merely investigate suspected wrong-doing and discuss that investigation with co-employees or supervisors. 15 See Faust v. Ryder Comm. Leasing & Servs., 954 S.W.2d 383, 391 (Mo.Ct.App.l997)(recognizing that a wrongful discharge claim may exist where there is a clear mandate of public policy and where the “ ‘whistleblowing’ actually occurred in that [the employee] reported the alleged criminal wrongdoing to the pr

2002To qualify for the public policy exception to at-will employment, the employee must report the suspected criminal activity to the appropriate law enforcement or judicial official, not merely investigate suspected wrong-doing and discuss that investigation with co-employees or supervisors. [15] See Faust v. Ryder Comm. Leasing & Servs., 954 S.W.2d 383, 391 (Mo.Ct.App.1997)(recognizing that a wrongful discharge claim may exist where there is a clear mandate of public policy and where the "`whistleblowing' actually occurred in that [the employee] reported the alleged criminal wrongdoing to the pr

11
City of Virginia Beach v. Harrisgreen
va · 2000 · cited in 1 Maryland opinions naming this issue, 2001–2001
1 sentence

2001With regard to the liability of the City of Virginia Beach, it observed that, under Virginia law, an at-will employee may recover in a wrongful discharge claim if he can show that his termination was in contravention of a statute “designed to protect the ‘property rights, personal freedoms, health, safety, or welfare of the people in general.’ ” Id. at 245 (citation omitted).

11
Crowe v. Houseworthgreen
md · 1974 · cited in 1 Maryland opinions naming this issue, 2000–2000
2 sentences

2000See Crowe, 272 Md. at 485-86 , 325 A.2d 592 .

2000See Crowe, 272 Md. at 485-86 , 325 A.2d 592 .

11
Collins v. Rizkanagreen
ohio · 1995 · cited in 1 Maryland opinions naming this issue, 1996–1996
2 sentences

1996Likewise, in Collins v. Rizkana, 73 Ohio St.3d 65 , 652 N.E.2d 653, 660-61 (1995), the Supreme Court of Ohio upheld a wrongful discharge claim based on the public policy in a statute prohibiting discrimination in employment from which the employer was exempt. 4 The legislature’s intent, the court said, was “to exempt small businesses from the burdens of [the Chapter], not from its antidiscrimination policy.” Id. 652 N.E.2d at 660-61 .

1996Likewise, in Collins v. Rizkana, 73 Ohio St.3d 65 , 652 N.E.2d 653, 660-61 (1995), the Supreme Court of Ohio upheld a wrongful discharge claim based on the public policy in a statute prohibiting discrimination in employment from which the employer was exempt. 4 The legislature’s intent, the court said, was “to exempt small businesses from the burdens of [the Chapter], not from its antidiscrimination policy.” Id. 652 N.E.2d at 660-61 .

11
Sullivan v. Snap-On Tools Corp.green
vaed · 1989 · cited in 1 Maryland opinions naming this issue, 1991–1991
11
United States Court of Appeals, Sixth Circuitgreen
ca6 · 1986 · cited in 1 Maryland opinions naming this issue, 1991–1991
11
David K. Pratt and Teri D. Pratt v. Brown MacHine Company, a Division of John Brown, Inc.green
ca6 · 1988 · cited in 1 Maryland opinions naming this issue, 1991–1991
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (19)

CaseCitedYears
Moniodis v. Cook green
mdctspecapp · 1985
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

41991–2005
Insignia Residential Corp. v. Ashton green
md · 2000
2 sentences

2011Insignia Residential Corp., 359 Md. at 561-562 , 755 A.2d at 1080-1081 . [8] To the extent that Ms. Parks has argued that cases from other jurisdictions and the Federal District Court for the District of Maryland support her claims that internal reports of employer misconduct are sufficient to constitute a wrongful discharge claim, or that adequate alternative remedies do not preclude her wrongful discharge claim in the instant case, we are not addressing those claims, nor the cases cited therein, for we affirm the circuit court's dismissal solely on the ground that Ms. Parks failed to identif

2011Insignia Residential Corp., 359 Md. at 561-562 , 755 A.2d at 1080-1081 . [8] To the extent that Ms. Parks has argued that cases from other jurisdictions and the Federal District Court for the District of Maryland support her claims that internal reports of employer misconduct are sufficient to constitute a wrongful discharge claim, or that adequate alternative remedies do not preclude her wrongful discharge claim in the instant case, we are not addressing those claims, nor the cases cited therein, for we affirm the circuit court's dismissal solely on the ground that Ms. Parks failed to identif

32003–2011
Joseph Szaller v. The American National Red Cross the American Red Cross Greater Chesapeake and Potomac Blood Services Region green
ca4 · 2002
2 sentences

2011In Szaller v. American National Red Cross, 293 F.3d 148 (4th Cir.2002), a Red Cross employee filed a wrongful discharge claim after allegedly being fired for reporting to a Red Cross hotline his suspicions that his co-workers and supervisors were engaging in "various blood handling and staff training deficiencies." Id. at 150 .

2011In Szaller v. American National Red Cross, 293 F.3d 148 (4th Cir.2002), a Red Cross employee filed a wrongful discharge claim after allegedly being fired for reporting to a Red Cross hotline his suspicions that his co-workers and supervisors were engaging in "various blood handling and staff training deficiencies." Id. at 150 .

22011–2016
Adler v. American Standard Corp. green
md · 1981
2 sentences

2011Rather, we are left with Ms. Parks's naked allegation that Alpharma was violating the Federal Trade Commission Act, a claim identical to that rejected in Adler , being far "too general, too conclusory, too vague, and lacking in specifics" to establish that Alpharma contravened a clear mandate of public policy. 291 Md. at 44 , 432 A.2d at 471 .

2011Rather, we are left with Ms. Parks's naked allegation that Alpharma was violating the Federal Trade Commission Act, a claim identical to that rejected in Adler , being far "too general, too conclusory, too vague, and lacking in specifics" to establish that Alpharma contravened a clear mandate of public policy. 291 Md. at 44 , 432 A.2d at 471 .

22003–2011
De Bleecker v. Montgomery County green
md · 1982
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

22002–2005
Ewing v. Koppers Co. green
md · 1988
2 sentences

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

22003–2005
Cladakis v. Miller green
scotus · 2015
1 sentence

2016Yuan counters with a reference to Weidman v. Exxon Mobil Corp., 776 F.3d 214 (4th Cir.2015) ce rt. denied, - U.S. -, 135 S.Ct. 2868 , 192 L.Ed.2d 897 (2015), which he says holds “that it was reversible error to dismiss a complaint that did not cite a specific statute, since the complaint identified and pled illegal activities, contrary to public policy.” Our reading of Weidman is a little different.

12016–2016
Tze Wung Consultants, Ltd. v. Bank of Baroda green
scotus · 2015
1 sentence

2016Yuan counters with a reference to Weidman v. Exxon Mobil Corp., 776 F.3d 214 (4th Cir.2015) ce rt. denied, - U.S. -, 135 S.Ct. 2868 , 192 L.Ed.2d 897 (2015), which he says holds “that it was reversible error to dismiss a complaint that did not cite a specific statute, since the complaint identified and pled illegal activities, contrary to public policy.” Our reading of Weidman is a little different.

12016–2016
Richard Weidman v. Exxon Mobil Corporation green
ca4 · 2015
1 sentence

2016Yuan counters with a reference to Weidman v. Exxon Mobil Corp., 776 F.3d 214 (4th Cir.2015) ce rt. denied, - U.S. -, 135 S.Ct. 2868 , 192 L.Ed.2d 897 (2015), which he says holds “that it was reversible error to dismiss a complaint that did not cite a specific statute, since the complaint identified and pled illegal activities, contrary to public policy.” Our reading of Weidman is a little different.

12016–2016
Finch v. Holladay-Tyler Printing, Inc. green
md · 1991
2 sentences

2007Finch, 322 Md. at 207 , 586 A.2d at 1280 .

2007Finch, 322 Md. at 207 , 586 A.2d at 1280 .

12007–2007
Gerald F. Adler v. American Standard Corporation, Gerald F. Adler v. American Standard Corporation green
ca4 · 1987
1 sentence

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

12005–2005
Donn Milton, Dr. v. Iit Research Institute green
ca4 · 1998
1 sentence

2005Co., 322 Md. 467 , 588 A.2d 760 (1991) (deciding that employee could not be fired for seeking legal redress from co-worker for sexual-harassment); Ewing, 312 Md. 45 , 537 A.2d 1173 (1988) (concluding that employee could not be fired for filing worker's compensation claim); De Bleecker v. Montgomery County, 292 Md. 498 , 438 A.2d 1348 (1982) (deciding that wrongful discharge action will lie for terminating an employee for exercising his First Amendment rights); Bleich v. Florence Crittenton Servs. of Baltimore, Inc., 98 Md.App. 123 , 632 A.2d 463 (1993) (permitting a wrongful discharge claim lo

12005–2005
Molesworth v. Brandon green
md · 1996
2 sentences

2003Vol.), Article 49B); Molesworth v. Brandon, 341 Md. 621 , 672 A.2d 608 (1996) (finding that although the public policy against employment discrimination set forth in Md.Code (1957, 1998 Repl.Vol.), Art. 49B, § 14, applies only to employers of more than 15 employees, nonetheless employers with fewer than 15 employees may be sued for wrongful discharge in violation of the public policy embodied in that statute); Ewing v. Koppers, 312 Md. 45 , 537 A.2d 1173 (1988) (recognizing a wrongful discharge claim predicated on the theory that the employee was discharged in retaliation for filing a worker's

2003Vol.), Article 49B); Molesworth v. Brandon, 341 Md. 621 , 672 A.2d 608 (1996) (finding that although the public policy against employment discrimination set forth in Md.Code (1957, 1998 Repl.Vol.), Art. 49B, § 14, applies only to employers of more than 15 employees, nonetheless employers with fewer than 15 employees may be sued for wrongful discharge in violation of the public policy embodied in that statute); Ewing v. Koppers, 312 Md. 45 , 537 A.2d 1173 (1988) (recognizing a wrongful discharge claim predicated on the theory that the employee was discharged in retaliation for filing a worker's

12003–2003
Miller v. Fairchild Industries, Inc. green
mdd · 1987
2 sentences

2003Vol.), Article 49B); Molesworth v. Brandon, 341 Md. 621 , 672 A.2d 608 (1996) (finding that although the public policy against employment discrimination set forth in Md.Code (1957, 1998 Repl.Vol.), Art. 49B, § 14, applies only to employers of more than 15 employees, nonetheless employers with fewer than 15 employees may be sued for wrongful discharge in violation of the public policy embodied in that statute); Ewing v. Koppers, 312 Md. 45 , 537 A.2d 1173 (1988) (recognizing a wrongful discharge claim predicated on the theory that the employee was discharged in retaliation for filing a worker's

2003The cases that have recognized a public policy suggested by a plaintiff include Insignia Residential Corp. v. Ashton, 359 Md. 560 , 755 A.2d 1080 (2000) (allowing a wrongful discharge claim based on the theory that an employee was wrongfully discharged for refusing to acquiesce in "quid pro quo” sexual harassment in violation of Title VII of the Civil Rights Act of 1964 and Maryland Code (1957, 1998 Repl.Vol.), Article 49B); Molesworth v. Brandon, 341 Md. 621 , 672 A.2d 608 (1996) (finding that although the public policy against employment discrimination set forth in Md.Code (1957, 1998 Repl.V

12003–2003
Miller v. Fairchild Industries, Inc. green
mdctspecapp · 1993
2 sentences

2003Miller, 97 Md.App. at 337 , 629 A.2d at 1299 .

2003Miller, 97 Md.App. at 337 , 629 A.2d at 1299 .

12003–2003
Gaskins v. Marshall Craft Associates, Inc. green
mdctspecapp · 1996
2 sentences

2000It also ruled that the second claim was not legally viable because the public policy foundation for the tort claim was found in a statute that itself contained a remedy for vindicating those objectives. *239 On appeal, we held that the circuit court had erred in concluding that the first claim was preempted by federal law; we also held, however, that the court properly had dismissed the wrongful discharge claim because “the very statutes that [the plaintiff] relied on to establish her policy claim provided a remedy for her cause of action.” Id. at 715, 678 A.2d 615 (citations and footnote omit

2000In responding to the plaintiffs argument that the circuit court had abused its discretion in failing to grant her leave to amend (which, because of the disposition of the first issue, related only to the wrongful discharge claim), we explained that given that “there was nothing [the plaintiff] could have done within the scope of Rule 2-841(c) that would have made her complaint viable as to Count II[,]” the circuit court did not abuse its discretion in dismissing “that aspect of [her] claims without leave to amend.” Id. at 716 , 678 A.2d 615 .

12000–2000
Bennett v. Hardy green
wash · 1990
1 sentence

1996And, in Bennett v. Hardy, 113 Wash.2d 912 , 784 P.2d 1258 (1990), the Supreme Court of Washington held that a cause of action for wrongful discharge *635 was available based on a statute prohibiting age discrimination but providing no remedy.

11996–1996
Roy L. Spicer, Jr. v. Superintendent Turlington Attorney General of North Carolina green
ca4 · 1990
11991–1991
Lingle v. Norge Division of Magic Chef, Inc. green
scotus · 1988
11991–1991

Statutes the citing opinions construe

CFR § 21c.f.r.201.57 (3) USC § 42u.s.c.2000e (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 61 (1990–2025) WA 45 (1990–2024) OR 40 (1984–2025) CT 39 (1987–2025) MI 27 (1984–2022) IA 26 (1992–2025) NC 25 (1991–2026) PA 25 (1985–2025) CA 24 (1985–2026) NJ 22 (1988–2025) MO 19 (1989–2020) TX 16 (1991–2023) MD 15 (1991–2017) MT 14 (1994–2024) DC 11 (1991–2018) NY 10 (1989–2026) WI 10 (1989–2023) CO 10 (1990–2023) WV 10 (1997–2023) UT 9 (1998–2015) KY 9 (1985–2026) MN 9 (1991–2016) AZ 8 (1988–2023) OK 7 (1989–2022) IN 7 (1992–2019) MA 7 (1993–2006) NH 7 (1999–2019) KS 7 (1984–2023) AK 6 (1986–2024) AR 5 (1988–2025) VI 5 (1994–2015) NM 5 (1991–2004) SC 5 (1996–2015) IL 4 (1984–2022) VA 4 (1996–2012) LA 4 (1991–2015) TN 4 (1997–2019) HI 3 (2011–2016) FL 3 (1989–2018) ME 2 (1986–2019) WY 2 (2009–2014) AL 2 (1986–2011) NE 2 (2006–2006) ID 2 (2003–2014) NV 2 (1991–1995) SD 2 (2006–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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