Geary v. United States Steel Corporation

Summary

The Supreme Court of Pennsylvania affirmed dismissal of an at-will employee's wrongful-discharge complaint. The court declined to recognize a nonstatutory cause of action on the pleaded facts, holding that an employee has no action where the complaint discloses a plausible and legitimate reason for termination and no clear public policy mandate is violated. The dissent argued that the discharge for reporting a potentially dangerous product supported a public-policy-based wrongful-discharge claim.

Holdings

1. Where the complaint itself discloses a plausible and legitimate reason for terminating an at-will employment relationship and no clear mandate of public policy is violated, an at-will employee has no cause of action against the employer for wrongful discharge.
2. The complaint failed to state a claim because its allegations did not establish that United States Steel specifically intended to harm Geary, coerce him to violate the law, or accomplish another proscribed purpose.

Questions Presented

1. Whether Pennsylvania should recognize a nonstatutory tort cause of action for wrongful discharge of an at-will employee based on the employer's alleged malicious, abusive, or retaliatory motive.
2. Whether Geary's amended complaint stated a claim based on public policy because he was allegedly discharged after raising safety concerns about a company product.
3. Whether the amended complaint sufficiently alleged specific intent to harm or accomplish an ulterior, proscribed purpose.

Disposition

affirmed