Wednesday, November 13, 2013

Wright v. Shriners Hospital for Crippled Children case brief

Wright v. Shriners Hospital for Crippled Children case brief summary
589 N.E.2d 1241 (1992)

Appellants, an employer hospital and its administrator, sought direct review of an order from the Superior Court (Massachusetts), which, in an action brought by appellee employee, a nurse, against the hospital for wrongful termination and against the administrator for tortious interference, entered judgments in favor of the employee.


The nurse had been employed by the hospital and rose to the position of assistant director of nursing but at all times was an employee at-will until she was discharged. The nurse was discharged as a result of unfavorable comments she made during two separate surveys that were conducted by the hospital's national headquarters. 


  • On review the court found that the nurse's termination of her employment at-will in reprisal for her critical remarks to the survey team would not have violated public policy. 
  • The court held that employment at-will was terminable by either party without notice, for almost any reason or for no reason at all. 
  • The court rejected the nurse's argument that her termination was against public policy because although statutes required notification of abuse, the nurse testified that she did not consider the patient care that caused her concern to be abuse, neglect, or mistreatment, nor did she believe that there was an issue of physician incompetence. 
  • The court noted that the nurse's report was an internal matter and internal matters could not have been the basis of a public policy exception to the at-will rule.

The court reversed the judgment and remanded for entry of judgments for the hospital and the administrator because there was no public policy exception and there was no evidence that the administrator acted malevolently, for a spiteful, malignant purpose, unrelated to the legitimate corporate interest.

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