Coman v. Thomas Manufacturing Co., Inc., 325 N.C. 172

Summary

The Supreme Court of North Carolina held that an at-will employee stated a claim for wrongful discharge when allegedly terminated for refusing to violate federal motor-carrier safety regulations and falsify required records. The Court adopted a public-policy exception to the employment-at-will doctrine, reasoning that highway safety is an established public policy of North Carolina. A dissent argued that creating such an exception was a legislative function and that the employee might have an available federal remedy.

Holdings

1. North Carolina recognizes a public-policy exception to the employment-at-will doctrine: an employer may not terminate an at-will employee for an unlawful reason or purpose that contravenes public policy.
2. Coman stated a cause of action for wrongful discharge because his alleged discharge for refusing to drive in violation of federal regulations and falsify federal records contravened North Carolina's public policy favoring highway safety.
3. The federal supremacy-clause preemption issue was not before the court because it had not been raised and passed upon below.

Questions Presented

1. Whether North Carolina recognizes a public-policy exception to the employment-at-will doctrine.
2. Whether an at-will employee states a wrongful-discharge claim by alleging that the employer discharged him for refusing to violate federal motor-carrier safety regulations and falsify federally required records.
3. Whether the Supreme Court could review the constitutional preemption issue raised in a footnote.

Disposition

reversed