Sabine Pilot Service, Inc. v. Hauck

Summary

The Supreme Court of Texas affirmed the court of appeals’ reversal of summary judgment for Sabine Pilot Service, Inc. in an employee’s wrongful-discharge action. The court recognized a narrow public-policy exception to employment at will when an employee is discharged solely for refusing to perform an illegal act, and placed on the employee the burden of proving that reason by a preponderance of the evidence.

Holdings

1. Texas public policy, as expressed in state and federal laws carrying criminal penalties, creates a narrow exception to the employment-at-will doctrine for an employee discharged for the sole reason that the employee refused to perform an illegal act.
2. The employee must prove by a preponderance of the evidence that the discharge was for no reason other than the employee's refusal to perform an illegal act.
3. Summary judgment was improper because the employee's evidence, viewed in his favor, presented a legally cognizable claim and a fact issue concerning the reason for his discharge.

Questions Presented

1. Whether an employee's allegation that he was discharged solely for refusing to perform an illegal act states a cause of action under Texas law.
2. Whether summary judgment for the employer was proper when the employee presented evidence that he was discharged for refusing to perform an illegal act.

Disposition

affirmed