Sabine Pilot exception in Texas

2025Finally, Williams has not shown that his claims are within the Sabine Pilot exception that allows employees to recover damages by showing “by a preponderance of the evidence that his discharge was for no other reason than his refusal to perform an illegal act.” Sabine Pilot, 687 S.W.2d at 735 .

2025Finally, Williams has not shown that his claims are within the Sabine Pilot exception that allows employees to recover damages by showing “by a preponderance of the evidence that his discharge was for no other reason than his refusal to perform an illegal act.” Sabine Pilot, 687 S.W.2d at 735 .

2015See Winters v. Houston Chronicle Publishing Co., 795 S.W.2d 723, 724-25 (Tex. 1990) (declining to extend Sabine Pilot exception to include employees who are discharged for reporting illegal activities).

2012This evidence is not sufficient to support a Sabine Pilot cause of action.”); see also Winters, 795 S.W.2d at 723−24 (holding that employee who was fired after complaining about employer’s alleged illegal activities to upper-level management did not fall within Sabine Pilot exception to at-will employment); Louis v. Mobil Chem.

2015Texas Dep’t of Human Servs. v. Hinds, 904 SW.2d 629, 633 (Tex.1995); see Safeshred, Inc. v. Martinez, 365 S.W.3d 655, 664 (Tex.2012) (“A plaintiff may not bring a Sabine Pilot claim immediately after being asked to perform an .illegal activity, but must first refuse and be fired.”).

2015Texas Dep’t of Human Servs. v. Hinds, 904 SW.2d 629, 633 (Tex.1995); see Safeshred, Inc. v. Martinez, 365 S.W.3d 655, 664 (Tex.2012) (“A plaintiff may not bring a Sabine Pilot claim immediately after being asked to perform an .illegal activity, but must first refuse and be fired.”).

2019See D’Unger, 207 S.W.3d at 332 (“Sabine Pilot protects employees who are asked to commit a crime”); Mayfield, 970 S.W.2d at 187 (“To prevail on the Sabine Pilot exception to the employment-at-will doctrine, the terminated employee must prove his discharge was solely because he refused to perform an illegal act that could result in criminal penalties against him.”); Ran Ken, Inc. v. Schlapper, 963 S.W.2d 102, 105 (Tex. App.—Austin 1998, pet. denied) (“Necessary to the employee’s proof is evidence that the act could have resulted in criminal penalties against the employee.”).

2019See D’Unger, 207 S.W.3d at 332 (“Sabine Pilot protects employees who are asked to commit a crime”); Mayfield, 970 S.W.2d at 187 (“To prevail on the Sabine Pilot exception to the employment-at-will doctrine, the terminated employee must prove his discharge was solely because he refused to perform an illegal act that could result in criminal penalties against him.”); Ran Ken, Inc. v. Schlapper, 963 S.W.2d 102, 105 (Tex. App.—Austin 1998, pet. denied) (“Necessary to the employee’s proof is evidence that the act could have resulted in criminal penalties against the employee.”).

2019See D’Unger, 207 S.W.3d at 332 (“Sabine Pilot protects employees who are asked to commit a crime”); Mayfield, 970 S.W.2d at 187 (“To prevail on the Sabine Pilot exception to the employment-at-will doctrine, the terminated employee must prove his discharge was solely because he refused to perform an illegal act that could result in criminal penalties against him.”); Ran Ken, Inc. v. Schlapper, 963 S.W.2d 102, 105 (Tex. App.—Austin 1998, pet. denied) (“Necessary to the employee’s proof is evidence that the act could have resulted in criminal penalties against the employee.”).

2019See D’Unger, 207 S.W.3d at 332 (“Sabine Pilot protects employees who are asked to commit a crime”); Mayfield, 970 S.W.2d at 187 (“To prevail on the Sabine Pilot exception to the employment-at-will doctrine, the terminated employee must prove his discharge was solely because he refused to perform an illegal act that could result in criminal penalties against him.”); Ran Ken, Inc. v. Schlapper, 963 S.W.2d 102, 105 (Tex. App.—Austin 1998, pet. denied) (“Necessary to the employee’s proof is evidence that the act could have resulted in criminal penalties against the employee.”).

2009The court in Nguyen v. Technical & Scientific Application, Inc., 981 S.W.2d 900 (Tex. *632 App.-Houston [1st Dist.] 1998, no pet.) held the Sabine Pilot exception to the employment-at-will doctrine applies to employees who are constructively discharged for the sole reason that they refuse to commit a crime.

2009The court in Nguyen v. Technical & Scientific Application, Inc., 981 S.W.2d 900 (Tex. *632 App.-Houston [1st Dist.] 1998, no pet.) held the Sabine Pilot exception to the employment-at-will doctrine applies to employees who are constructively discharged for the sole reason that they refuse to commit a crime.

2009Texas Division-Tranter, Inc. v. Carrozza, 876 S.W.2d 312, 314 (Tex.1994) (retaliatory discharge claim); Robinson v. The Devereux Foundation, No. 14-01-00081-CV, 2002 WL 1315631 (Tex.App.-Houston [14th Dist.] June 6, 2002, pet. denied) (mem. op.) (Sabine Pilot claim).

2009Texas Division-Tranter, Inc. v. Carrozza , 876 S.W.2d 312, 314 (Tex. 1994) (retaliatory discharge claim); Robinson v. The Devereaux Foundation, No. 14-01-00081-CV, 2002 WL 1315631 (Tex.App.–Houston [14 th Dist.] June 6, 2002, pet. denied) (mem. op.) ( Sabine Pilot claim).

2018See Safeshred , 365 S.W.3d at 662 ("A malice finding must require more than Safeshred's mere intent to fire Martinez, or else every Sabine Pilot claim would warrant punitive damages."); Cont'l Coffee , 937 S.W.2d at 454 ; Moriel , 879 S.W.2d at 18 .

2015Texas Dep’t of Human Servs. v. Hinds, 904 SW.2d 629, 633 (Tex.1995); see Safeshred, Inc. v. Martinez, 365 S.W.3d 655, 664 (Tex.2012) (“A plaintiff may not bring a Sabine Pilot claim immediately after being asked to perform an .illegal activity, but must first refuse and be fired.”).

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff’s claim that he was fired in retaliation for investigating employer’s actions was inconsistent with his Sabine Pilot claim); Pease v. Pak- hoed Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff's claim that he was fired in retaliation for investigating employer's actions was inconsistent with his Sabine Pilot claim); Pease v. Pakhoed *754 Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2010See Ran Ken, 963 S.W.2d at 106 ; see also Johansen v. Combustion Eng'g, Inc., 170 F.3d 1320 , 1338-39 (11th Cir.1999) (upholding ratio of 100 to 1 and noting the state's strong interest in deterring the corporate defendant's conduct *666 of environmental pollution).

2010See Ran Ken, 963 S.W.2d at 106 ; see also Johansen v. Combustion Eng'g, Inc., 170 F.3d 1320 , 1338-39 (11th Cir.1999) (upholding ratio of 100 to 1 and noting the state's strong interest in deterring the corporate defendant's conduct *666 of environmental pollution).

2009See, e.g., Fite v. Cherokee Water Co., 6 S.W.3d 337, 342 (Tex. App.–Texarkana 1999, no pet.) (refusing to expand Sabine Pilot to statutes that have no penalties); Mayfield v. Lockheed Eng’g & Scis.

2009See, e.g., Fite v. Cherokee Water Co., 6 S.W.3d 337, 342 (Tex. App.–Texarkana 1999, no pet.) (refusing to expand Sabine Pilot to statutes that have no penalties); Mayfield v. Lockheed Eng’g & Scis.

2018See Safeshred , 365 S.W.3d at 662 ("A malice finding must require more than Safeshred's mere intent to fire Martinez, or else every Sabine Pilot claim would warrant punitive damages."); Cont'l Coffee , 937 S.W.2d at 454 ; Moriel , 879 S.W.2d at 18 .

2015Compare Safeshred, 365 S.W.3d at 662 (confirming sole causation standard for Sabine Pilot claim), with Cazarez, 937 S.W.2d at 451 n. 3 (stating that- plaintiff need not prove that filing of workers’ compensation claim was sole cause of her termination).

2010See Federal Express Corp. v. Dutschmann, 846 S.W.2d 282 (Tex. 1993); Nagel Mfg. & Supply v. Ulloa, 812 S.W.2d 78 (Tex.App.- Austin 1991 , writ denied).

2010See Federal Express Corp. v. Dutschmann, 846 S.W.2d 282 (Tex. 1993); Nagel Mfg. & Supply v. Ulloa, 812 S.W.2d 78 (Tex.App.- Austin 1991 , writ denied).

2010See, e.g., Jasper, 764 N.W.2d at 775-76 ; Ballinger, 800 A.2d at 110-11 ; Harless, 289 S.E.2d at 698-700 .

2010See, e.g., Jasper, 764 N.W.2d at 775-76 ; Ballinger, 800 A.2d at 110-11 ; Harless, 289 S.E.2d at 698-700 .

2009See Paul v. P.B.-K.B.B., Inc., 801 S.W.2d 229, 230 (Tex. App.–Houston [14th Dist.] 1990, writ denied); see also Fitch v. Reliant Pharm., LLC, No. Civ.A.4:04-CV-615-Y, 2006 WL 325759 at *3 (N.D.

2009See Paul v. P.B.-K.B.B., Inc., 801 S.W.2d 229, 230 (Tex. App.–Houston [14th Dist.] 1990, writ denied); see also Fitch v. Reliant Pharm., LLC, No. Civ.A.4:04-CV-615-Y, 2006 WL 325759 at *3 (N.D.

2009Similarly, in White, the Fifth Circuit held that there was unrefuted evidence of an ongoing reduction-in-force and financial difficulties and affirmed a summary judgment, holding that the employee did not come within the Sabine Pilot exception of the employment-at-will doctrine under Texas law. 319 F.3d at 674 .

2009Similarly, in White, the Fifth Circuit held that there was unrefuted evidence of an ongoing reduction-in-force and financial difficulties and affirmed a summary judgment, holding that the employee did not come within the Sabine Pilot exception of the employment-at-will doctrine under Texas law. 319 F.3d at 674 .

2008Id.; see also Conley, 175 S.W.3d at 887 n. 4 (explaining that intentional infliction of emotional distress tort cannot be used as an alternative to some other, more conventional tort that fits the facts but might be subject to some structural impediment).

2008Id.; see also Conley, 175 S.W.3d at 887 n. 4 (explaining that intentional infliction of emotional distress tort cannot be used as an alternative to some other, more conventional tort that fits the facts but might be subject to some structural impediment).

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff’s claim that he was fired in retaliation for investigating employer’s actions was inconsistent with his Sabine Pilot claim); Pease v. Pak- hoed Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff's claim that he was fired in retaliation for investigating employer's actions was inconsistent with his Sabine Pilot claim); Pease v. Pakhoed *754 Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff’s claim that he was fired in retaliation for investigating employer’s actions was inconsistent with his Sabine Pilot claim); Pease v. Pak- hoed Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff's claim that he was fired in retaliation for investigating employer's actions was inconsistent with his Sabine Pilot claim); Pease v. Pakhoed *754 Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff’s claim that he was fired in retaliation for investigating employer’s actions was inconsistent with his Sabine Pilot claim); Pease v. Pak- hoed Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2008See Robertson v. Bell Helicopter Textron, Inc., 32 F.3d 948, 952-53 (5th Cir.1994), cert. denied, 513 U.S. 1154 , 115 S.Ct. 1110 , 130 L.Ed.2d 1075 (1995) (affirming dismissal of Sabine Pilot claim, and holding that plaintiff's claim that he was fired in retaliation for investigating employer's actions was inconsistent with his Sabine Pilot claim); Pease v. Pakhoed *754 Corp., 980 F.2d 995 , 997 n. 1 (5th Cir.1993) (Plaintiff who brings Sabine Pilot claim cannot advance additional claims); Schutze v. Financial Computer Software, No. 3:04-CV-0276-H, 2006 WL 2842008 , at *7 (N.D.Tex.

2014See Watley, 216 S.W.3d at 376 ; Salazar, 88 S.W.3d at 353 ; Hohman, 6 S.W.3d at 777 ; Carroll, 938 S.W.2d at 134–35.

2014See Watley, 216 S.W.3d at 376 ; Salazar, 88 S.W.3d at 353 ; Hohman, 6 S.W.3d at 777 ; Carroll, 938 S.W.2d at 134–35.

2014See Watley, 216 S.W.3d at 376 ; Salazar, 88 S.W.3d at 353 ; Hohman, 6 S.W.3d at 777 ; Carroll, 938 S.W.2d at 134–35.

2014See Watley, 216 S.W.3d at 376 ; Salazar, 88 S.W.3d at 353 ; Hohman, 6 S.W.3d at 777 ; Carroll, 938 S.W.2d at 134–35.