12 Colorado opinions name it 2 courts 1991–2026 3 in the last five years
The cases below were cited by Colorado 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.
| Case | Followed | Cited |
|---|---|---|
Martin Marietta Corp. v. Lorenzgreen2 sentences2026We accepted jurisdiction under C.A.R. 21.1 to answer the following question of law certified to us by the United States District Court for the District of Colorado: Does Colorado law recognize a public-policy exception to the at-will employment doctrine that allows an employee to bring a wrongful termination claim in the event the employee is terminated for actions taken in self-defense? ¶2 This court first recognized a public-policy exception to the at-will employment doctrine in Martin Marietta Corp. v. Lorenz , 823 P.2d 100, 109 (Colo. 1992). 2026When a party claims a public-policy exception to the at-will employment doctrine, we consider if "the discharge of the employee contravenes a clear mandate of public policy." Mariani , 916 P.2d at 523-24 (quoting Martin Marietta, 823 P.2d at 107). | 3 | 8 |
Frampton v. Central Indiana Gas Companygreen2 sentences2026See id. at 110; see also Frampton, 297 N.E.2d at 427-28 (analogizing wrongful termination in violation of public policy to retaliatory eviction). ¶56 Self-defense is certainly no less important a right to a worker than workers' compensation, which is not a "right" at all but which our court of appeals and other jurisdictions have recognized as giving rise to a public-policy exception to the at-will employment doctrine. 2026See id. at 110 ; see also Frampton , 297 N.E.2d at 427-28 (analogizing wrongful termination in violation of public policy to retaliatory eviction) . ¶56 Self-defense is certainly no less important a right to a worker than workers' compensation, which is not a "right" at all but which our court of appeals and other jurisdictions have recognized as giving rise to a public-policy exception to the at-will employment doctrine. | 1 | 2 |
Hoyt v. Target Stores, Division of Dayton Hudson Corp.green2 sentences2022Co. , 997 P.2d 1238, 1240 (Colo. App. 1999) (holding that because the Federal Employers’ Liability Act provi ded the employee the “right to seek compensation for his work-r elated injury,” it constituted “a recognized public policy exception to the at-will employment doctrine”); Hoyt v. Target Store s , 981 P.2d 188, 192 (Colo. App. 1998) (holding that “the Colorado Wage Claim Act clearly establishes as public policy that employees are entitled to be paid for the time they work”). 2001See Coors Brewing Co. v. Floyd, 978 P.2d 663 (Colo.1999); Martin Marietta Corp. v. Lorenz, supra; Hoyt v. Target Stores, 981 P.2d 188 (Colo.App.1998). | 1 | 2 |
Continental Air Lines, Inc. v. Keenangreen2 sentences2018But we also know from the plain language of the amended statute that in other respects, the General Assembly intended to preserve the doctrine of at-will employment. ¶6 Considering the plain language of the 2006 amendments, the legislative history, and commonly recognized rules of statutory construction, we conclude that section 30-10-506 does the following: It grants two unwaivable rights to the deputies: the right of notification “of the reason for the proposed revocation” of their employment, and “an opportunity to be heard by the sheriff” before their employment is terminated. It requi 2002See Martin Marietta Corp. v. Lorenz, supra; Continental Air Lines, Inc. v. Keenan, supra. Unless the plaintiff pleads and proves a recognized exception to the at-will employment doctrine, see Schur v. Storage Technology Corp., supra, the doctrine restrains courts from inquiring into the basis for termination and advances the value of a free market in employment for which the parties bargained. | 1 | 2 |
Legislative Reapportionment v. General Assemblygreen2 sentences2026Reapportionment , 374 P.2d 66, 68 18 (Colo. 1962) ("The judicial branch of the government has imposed upon it the obligation of interpreting the [c]onstitution and of safeguarding the basic rights granted thereby to the people." (quoting Asbury Park Press, Inc. v. Woolley , 161 A.2d 705, 710 (N.J. 1960))). ¶38 With both the statutory and constitutional text in mind, we now consider whether either provision is sufficient to establish self-defense as a public-policy exception to the at-will employment doctrine. 2026Reapportionment , 374 P.2d 66, 68 ( Colo. 1962 ) ( "The judicial branch of the government has imposed upon it the obligation of interpreting the [c] onstitution and of safeguarding the basic rights granted thereby to the people ." ( quoting Asbury Park Press, Inc. v. Woolley , 161 A.2d 705, 710 ( N.J. 1960 ) ) ) . ¶38 With both the statutory and constitutional text in mind, we now consider whether either provision is sufficient to establish self-defense as a public-policy exception to the at-will employment doctrine. | 1 | 1 |
Rocky Mountain Hospital & Medical Service v. Marianigreen2 sentences2026When a party claims a public-policy exception to the at-will employment doctrine, we consider if "the discharge of the employee contravenes a clear mandate of public policy." Mariani , 916 P.2d at 523-24 (quoting Martin Marietta, 823 P.2d at 107). 2026When a party claims a public-policy exception to the at-will employment doctrine, we consider if "the discharge of the employee contravenes a clear mandate of public policy." Mariani , 916 P.2d at 523-24 ( quoting Martin Marietta , 823 P.2d at 107 ) . | 1 | 1 |
Thompson v. St. Regis Paper Companygreen2 sentences2026Regis Paper Co. , 685 P.2d 1081, 1089 (Wash. 1984)). ¶74 We have traditionally taken a cautious approach to announcing publicpolicy exceptions to at-will employment because "expansive definition[s] of public policy would be both unwieldy and unpredictable leaving employers and employees alike without direction as to the contours of the public policy exception." Rocky Mountain Hosp. &Med. 2026Regis Paper Co. , 685 P.2d 1081, 1089 ( Wash. 1984 ) ) . ¶74 We have traditionally taken a cautious approach to announcing publicpolicy exceptions to at-will employment because "expansive definition [s] of public policy would be both unwieldy and unpredictable leaving employers and employees alike without direction as to the contours of the public policy exception." Rocky Mountain Hosp. &Med. | 1 | 1 |
Crawford Rehabilitation Services, Inc. v. Weissmangreen2 sentences2026II, § 3, coupled with the right to act in defense of property under section 18-1-706, establishes a publicpolicy exception to the doctrine of at-will employment. ¶102 Before today, our case law would have indicated that the right to defend property is a purely personal interest and not one that "affect[s] society at large." Weissman , 938 P.2d at 552. 2026II, § 3 , coupled with the right to act in defense of property under section 18-1-706 , establishes a publicpolicy exception to the doctrine of at-will employment. ¶102 Before today, our case law would have indicated that the right to defend property is a purely personal interest and not one that "affect [s] society at large." Weissman , 938 P.2d at 552 . | 1 | 1 |
Jones v. Stevinson's Golden Fordgreen2 sentences2026See Jones v. Stevinson's Golden Ford , 36 P.3d 129, 133 (Colo.App. 2001) (concluding that a public-policy exception to the at-will employment doctrine exists based on "[t]he broad legislative purpose of the Colorado Consumer Protection Act"). ¶29 A statute or comparable provision, however, need not proscribe or prescribe specific actions to give rise to a public-policy exception. 2026See Jones v. Stevinson's Golden Ford , 36 P.3d 129, 133 ( Colo.App. 2001 ) ( concluding that a public-policy exception to the at-will employment doctrine exists based on " [t] he broad legislative purpose of the Colorado Consumer Protection Act " ) . ¶29 A statute or comparable provision, however, need not proscribe or prescribe specific actions to give rise to a public-policy exception. | 1 | 1 |
Asbury Park Press, Inc. v. Woolleygreen2 sentences2026Reapportionment , 374 P.2d 66, 68 18 (Colo. 1962) ("The judicial branch of the government has imposed upon it the obligation of interpreting the [c]onstitution and of safeguarding the basic rights granted thereby to the people." (quoting Asbury Park Press, Inc. v. Woolley , 161 A.2d 705, 710 (N.J. 1960))). ¶38 With both the statutory and constitutional text in mind, we now consider whether either provision is sufficient to establish self-defense as a public-policy exception to the at-will employment doctrine. 2026Reapportionment , 374 P.2d 66, 68 ( Colo. 1962 ) ( "The judicial branch of the government has imposed upon it the obligation of interpreting the [c] onstitution and of safeguarding the basic rights granted thereby to the people ." ( quoting Asbury Park Press, Inc. v. Woolley , 161 A.2d 705, 710 ( N.J. 1960 ) ) ) . ¶38 With both the statutory and constitutional text in mind, we now consider whether either provision is sufficient to establish self-defense as a public-policy exception to the at-will employment doctrine. | 1 | 1 |
Jeremy Hoven v. Walgreen Co.green2 sentences2026Hoven , 751 F.3d at 784 ("[U]nder Michigan law, constitutional provisions may not be the source of a claim for termination in violation of public policy against a private employer."). 2026Hoven , 751 F.3d at 784 ( " [U] nder Michigan law, constitutional provisions may not be the source of a claim for termination in violation of public policy against a private employer." ) . | 1 | 1 |
Herrera v. San Luis Central Railroad Co.green1 sentence2022Co. , 997 P.2d 1238, 1240 (Colo. App. 1999) (holding that because the Federal Employers’ Liability Act provi ded the employee the “right to seek compensation for his work-r elated injury,” it constituted “a recognized public policy exception to the at-will employment doctrine”); Hoyt v. Target Store s , 981 P.2d 188, 192 (Colo. App. 1998) (holding that “the Colorado Wage Claim Act clearly establishes as public policy that employees are entitled to be paid for the time they work”). | 1 | 1 |
Interrogatory of United States District Court: First Interstate Bank of Fort Collins, N.A. v. Piper Aircraft Corp.green2 sentences2002Cf. First Interstate Bank v. Piper Aircraft Corp., 744 P.2d 1197 (Colo.1987)(fraudulent concealment of 2 wrongful act tolls the limitations period). 2002Cf. First Interstate Bank v. Piper Aircraft Corp., 744 P.2d 1197 (Colo.1987)(fraudulent concealment of a wrongful act tolls the limitations period). | 1 | 1 |
Coors Brewing Co. v. Floydgreen1 sentence2001See Coors Brewing Co. v. Floyd, 978 P.2d 663 (Colo.1999); Martin Marietta Corp. v. Lorenz, supra; Hoyt v. Target Stores, 981 P.2d 188 (Colo.App.1998). | 1 | 1 |
People in Interest of CAKgreen2 sentences1992In addition, the court of appeals concluded that, under Colorado’s test for retroactive application of a judicial decision, see People in Interest of C.A.K., 652 P.2d 603, 607 (1982), the Cronk decision should be retroactively applied to Lorenz’s claim because it involved conduct that was clearly prohibited by federal law, because retroactive application would further the purpose and effect of the public-policy exception to the at-will employment doctrine, and because the equities favored retroactive application in order to avoid penalizing Lorenz for his responsible actions and releasing Mart 1992In addition, the court of appeals concluded that, under Colorado's test for retroactive application of a judicial decision, see People in Interest of C.A.K., 652 P.2d 603, 607 (1982), the Cronk decision should be retroactively applied to Lorenz's claim because it involved conduct that was clearly prohibited by federal law, because retroactive application would further the purpose and effect of the public-policy exception to the at-will employment doctrine, and because the equities favored retroactive application in order to avoid penalizing Lorenz for his responsible actions and releasing Mart | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Lathrop v. ENTERNMANN'S, INC.
green
2 sentences1992The Cronk public-policy exception to the at-will employment doctrine was somewhat expanded in Lathrop v. Entenmann’s, Inc., 770 P.2d 1367 (Colo.App.1989). 1992The Cronk public-policy exception to the at-will employment doctrine was somewhat expanded in Lathrop v. Entenmann's, Inc., 770 P.2d 1367 (Colo.App.1989). | 2 | 1992–2022 |
Cronk v. Intermountain Rural Electric Ass'n
green
2 sentences1992We thus conclude that Lorenz did present sufficient evidence at trial to establish a prima facie case for wrongful discharge under the public-policy exception to the at-will employment doctrine, as outlined in Cronk, 765 P.2d 619 . 1992We thus conclude that Lorenz did present sufficient evidence at trial to establish a prima facie case for wrongful discharge under the public-policy exception to the at-will employment doctrine, as outlined in Cronk, 765 P.2d 619 . | 2 | 1991–1992 |
Jaynes v. Centura Health Corp.
green
1 sentence2026Jaynes applied Martin Marietta. 148 P.3d at 243 . | 1 | 2026–2026 |
JULESBURG SCH. DIST. NO. RE-1, ETC. v. Ebke
green
2 sentences2022No. RE-1 , 37 Colo. App. 349 , 351, 550 P.2d 355 , 358 (1976), a ff’d , 193 Colo. 40 , 562 P.2d 419 (1977). ¶ 10 Denver Health specifically asserted that Castillo’s claims “qualify for the public policy excep tion[] to the at-will employment doctrine” because she alleged that she suffered retaliation “for whistleblowing about ethical and c ompliance concerns at a hospital.” As explained below, clai ms arising from retaliation for whistleblowing lie in tort. 2022No. RE-1 , 37 Colo. App. 349 , 351, 550 P.2d 355 , 358 (1976), a ff’d , 193 Colo. 40 , 562 P.2d 419 (1977). ¶ 10 Denver Health specifically asserted that Castillo’s claims “qualify for the public policy excep tion[] to the at-will employment doctrine” because she alleged that she suffered retaliation “for whistleblowing about ethical and c ompliance concerns at a hospital.” As explained below, clai ms arising from retaliation for whistleblowing lie in tort. | 1 | 2022–2022 |
Berger v. Security Pacific Information Systems, Inc.
green
2 sentences2002In Berger v. Security Pacific Information Systems, Inc., 795 P.2d 1380 (Colo.App.1990), a division of this court upheld the fraud claim of an employee who relied on the employer's concealment of a fact that cast doubt on the longevity of their at-will relationship, without purporting to create an exception to the at-will employment rule. 2002In Berger v. Security Pacific Information Systems, Inc., 795 P.2d 1380 (Colo.App.1990), a division of this court upheld the fraud claim of an employee who relied on the employer's concealment of a fact that cast doubt on the longevity of their at-will relationship, without purporting to create an exception to the at-will employment rule. | 1 | 2002–2002 |
Johnson v. Regional Transportation District
green
1 sentence1999Rocky Mountain Hospital & Medical Service v. Mariani, supra. The public-policy exception to the at-will employment doctrine is grounded on the principle that an employer should be prohibited from discharging an employee for reasons that contravene substantial and widely accepted public policies. | 1 | 1999–1999 |
Lorenz v. Martin Marietta Corp., Inc.
green
2 sentences1992Lorenz, 802 P.2d at 1150 . 1992Lorenz, 802 P.2d at 1150 . | 1 | 1992–1992 |
Cloutier v. Great Atlantic & Pacific Tea Co.
green
2 sentences1992Id. 436 A.2d at 1143 . 1 Cognizant of the varied interests implicated by the employment relationship, courts have engrafted on the at-will employment doctrine what has become known as the public-policy exception. 1992Id. 436 A.2d at 1143 . 1 Cognizant of the varied interests implicated by the employment relationship, courts have engrafted on the at-will employment doctrine what has become known as the public-policy exception. | 1 | 1992–1992 |
Russell v. Courier Printing & Publishing Co.
green
2 sentences1992These factors would include the following: four other states already had adopted the public-policy exception to the at-will employment doctrine, see Part 11(A), supra; this court had previously held in Russell, 43 Colo. 321 , 95 P. 936 , that contracts violative of public policy were unenforceable; and a 1948 federal statute prohibited a person from making a false or fraudulent statement to any department or agency of the United States, ch. 645, 62 Stat. 683 , 749 (presently codified at 18 U.S.C. § 1001 (1988)). 1992These factors would include the following: four other states already had adopted the public-policy exception to the at-will employment doctrine, see Part II(A), supra; this court had previously held in Russell, 43 Colo. 321 , 95 P. 936 , that contracts violative of public policy were unenforceable; and a 1948 federal statute prohibited a person from making a false or fraudulent statement to any department or agency of the United States, ch. 645, 62 Stat. 683 , 749 (presently codified at 18 U.S.C. § 1001 (1988)). | 1 | 1992–1992 |
Petermann v. International Brotherhood of Teamsters, Local 396
green
2 sentences1992This exception was first articulated in Petermann v. International Bhd. of Teamsters Local Union 396, 174 Cal.App.2d 184 , 344 P.2d 25 (1959). 1992This exception was first articulated in Petermann v. International Bhd. of Teamsters Local Union 396, 174 Cal.App.2d 184 , 344 P.2d 25 (1959). | 1 | 1992–1992 |
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.
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.