Donaldson v. Informatica Corp., 2011 U.S. Dist. LEXIS 57943 (W.D. Pa. May 31, 2011)

District court holds that the public policy exemption to at-will employment does not extend to wage payment-related retaliatory discharge claims.

The plaintiff filed a wrongful discharge claim against his former employer, alleging his employment was terminated in retaliation for filing a prior lawsuit against his employer, which alleged violations of the Pennsylvania Wage Payment and Collection Law. In rejecting the plaintiff's claim, the court held that the plaintiff's theory does not support a wrongful discharge claim under Pennsylvania law. In so holding, the court first noted that "[t]he presumption of at-will employment is strong, and an employee may bring a cause of action for a termination of that employment only in the most limited circumstances, where the termination implicates a clear mandate of public policy." With that background in mind, the court noted that the Pennsylvania Supreme Court directly found a public policy exception to at-will employment in two circumstances, both of which involved workers' compensation claims. In predicting that the Pennsylvania Supreme Court would not permit a wrongful discharge claim premised on the prior filing of a lawsuit pursuant to the Pennsylvania Wage Payment and Collection Law, the court reasoned that while the Workers' Compensation Act "creates a substantive duty in the employer to compensate employees for work-related injuries" and "is the exclusive means for obtaining compensation for [work-related] injuries," these characteristics are not shared in the Pennsylvania Wage Payment and Collection Law. Specifically, the court determined that "the [Wage Payment and Collection Law] does not create a substantive right to compensation, but rather provides a statutory remedy when an employer breaches a contractual obligation to pay earned wages" and "[t]he [Wage Payment and Collection Law] also is not an employee's exclusive remedy for obtaining wages allegedly due." As a result, the court rejected the plaintiff's wrongful discharge claim and found that "the public policy exception to at-will employment does not extend to wage payment-related retaliatory discharge claim" under Pennsylvania law.

Case Law Alert - 3rd Qtr 2011