MacKenzie v. Linehan, 158 N.H. 476

Summary

The Supreme Court of New Hampshire reviewed the post-verdict judgment in a wrongful discharge and false imprisonment action brought by a deputy sheriff against the Rockingham County sheriff and county. The court affirmed judgment notwithstanding the verdict on the wrongful discharge claim, holding that the evidence did not support a public-policy basis for the termination, but reversed on the false imprisonment claim because a rational jury could find that the sheriff unlawfully confined the plaintiff by blocking the hearing-room door. Because the jury returned a general verdict, the court remanded for a new trial on the false imprisonment claim.

Holdings

1. The trial court properly granted JNOV on the wrongful discharge claim because the evidence did not permit a rational juror to find that MacKenzie was terminated for refusing to lie, for expressing disagreement with management, or for protecting his off-duty time.
2. An employer's supervisory or employment relationship with an employee does not, by itself, provide legal authority to detain the employee in a disciplinary hearing room by physically blocking the door.
3. Because the jury returned a general verdict and the court could not determine whether the verdict or the damages award rested on the false imprisonment claim, the proper remedy was reversal and remand for a new trial on that claim.

Questions Presented

1. Whether the trial court properly granted JNOV on MacKenzie's wrongful discharge claim because no rational juror could find that his termination was motivated by conduct protected by public policy.
2. Whether the trial court properly granted JNOV on MacKenzie's false imprisonment claim because Linehan had legal authority to detain MacKenzie during the disciplinary hearing.
3. Whether reversal of the false imprisonment JNOV required a new trial because the jury returned a general verdict and the reviewing court could not determine the basis for the $500,000 award.

Disposition

reversed_and_remanded