Summary
The North Dakota Supreme Court affirmed summary judgment for the City of Devils Lake and the Devils Lake Police Department in Brandon Potts’s wrongful-termination action. The court held that North Dakota law does not recognize a public-policy exception to the employment-at-will doctrine for law enforcement officers acting in self-defense. A concurrence would have foreclosed judicial recognition of any additional public-policy exceptions to the statutory at-will rule.
Holdings
- North Dakota law does not recognize a public-policy exception to the employment-at-will doctrine for law-enforcement officers who act in self-defense.
- Summary judgment for the defendants was proper because the issue was a question of law and no legally cognizable public-policy exception supported Potts's wrongful-termination claim.
Questions Presented
- Whether North Dakota law recognizes a public-policy exception to the employment-at-will doctrine for law-enforcement officers who act in self-defense while performing official duties.
- Whether the district court properly granted summary judgment to the City of Devils Lake and the Devils Lake Police Department.
Disposition
affirmed
Cases Cited (29)
- McCormick, Inc. v. Fredericks, 2020 ND 161, 946 N.W.2d 728(followed)
- Krebsbach v. Trinity Hosps., Inc., 2020 ND 24, 938 N.W.2d 133(followed)
- Yahna v. Altru Health Sys., 2015 ND 275, 871 N.W.2d 580(followed)
- Dahlberg v. Lutheran Soc. Servs. of N.D., 2001 ND 73, 625 N.W.2d 241(followed)
- Jose v. Norwest Bank, 1999 ND 175, 599 N.W.2d 293(followed)
- Spratt v. MDU Res. Grp., Inc., 2011 ND 94, 797 N.W.2d 328(followed)
- Hunt v. Banner Health Sys., 2006 ND 174, 720 N.W.2d 49(followed)
- Ressler v. Humane Soc., 480 N.W.2d 429 (N.D. 1992)(followed)
- Krein v. Marian Manor Nursing Home, 415 N.W.2d 793 (N.D. 1987)(followed)
- Lee v. Walstad, 368 N.W.2d 542 (N.D. 1985)(followed)
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Cited In (0)
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Court Document
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