King v. Berryhill Fire Protection District

Summary

The Oklahoma Supreme Court affirmed a jury verdict finding that Steven King was wrongfully terminated for opposing and attempting to prevent an allegedly unlawful and unsafe fire-training exercise. The court held that whether the proposed burning constituted arson or was merely a legitimate training exercise presented a factual issue for the jury. The court also rejected Berryhill's arguments that trial errors warranted a new trial.

Holdings

1. The Court of Civil Appeals erred by holding that the proposed burning could not constitute arson as a matter of law. Whether the purported training exercise was a legitimate burn with just cause or excuse, or a pretext for an unlawful burning, was a factual issue for the jury.
2. An employer's termination of an at-will employee for exposing and opposing an unlawful and unsafe practice violates Oklahoma's clear public policy and constitutes a tortious breach of contractual obligations when the employee's conduct furthers that policy.
3. The trial court's judgment on the jury verdict must be affirmed because the record contained competent evidence supporting the verdict and no fundamental error occurred in the trial.
4. Berryhill was not entitled to a new trial, and the damages were not excessive, because King established the wages he would have earned but for the wrongful termination through the date of trial and any assumed errors were harmless in light of the jury's resolution of the pivotal credibility issue.

Questions Presented

1. Whether the evidence supported King's claim that his termination violated a clear mandate of Oklahoma public policy.
2. Whether the proposed burning of the fire chief's structures could be deemed arson as a matter of law, or whether that issue was for the jury.
3. Whether the alleged evidentiary, instructional, and trial-management errors required a new trial.
4. Whether the jury's damages award was excessive.

Disposition

vacated