Haddle v. Garrison

Michael A. Haddle was an employee for Healthmaster, Inc, when his employers, Jeanette Garrison and Dennis Kelly, fired him for his continued involvement in a separate criminal trial against Healthmaster. Healthmaster was under investigation for medicaid fraud at the time. Haddle had obeyed a federal grand jury subpoena and planned to testify against Healthmaster as a witness. As a result, Haddle was wrongly ousted from his job for merely following the law and contributing to the course of justice. In his claim, he noted that his employer’s actions had “injured [him] in his person or property.” He maintained this was a breach of federal law under the Civil Rights Act of 1871.

The instant case posed the question of whether an at-will employee may sue their employer(s) over firings which allegedly constitute retaliation on the grounds of unfavorable testimony.

The U.S. government submitted an amicus brief was submitted in support of Haddle. The brief calls upon the legislative history of federal judicial proceedings. It further explains how the clause Haddle called upon, Conspiracy to Interfere with Civil Rights, is used to protect the integrity of federal judicial proceedings as it encourages witnesses to come forward and speak without hesitation of retaliatory punishment. This is a key tool in the fortification and protection of the U.S government and its economy.

On December 4, 1998, the Supreme Court ruled in favor of Haddle by reversing the judgement of the 11th Circuit Court of Appeals and ordering that the case be remanded under that opinion. The full decision can be found here. This marked a significant victory for whistleblower protection legislation because it demonstrated that retaliatory actions against whistleblowers will not be tolerated, thus encouraging whistleblowers to come forward and help expose fraudulent schemes. The National Whistleblower Center (“NWC”) continues to work with both whistleblowers and legislators to ensure that whistleblowers are granted the protection they deserve.

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