Wednesday, December 25, 2013

Sheets v. Teddy's Frosted Foods case brief

Sheets v. Teddy's Frosted Foods case brief summary
427 A.2d 385 (1980)

Plaintiff employee appealed the order of the Superior Court in the Judicial District of Hartford-New Britain (Connecticut), which granted defendant employer's motion to strike the employee's complaint for wrongful discharge as legally insufficient.

Employee had worked as a quality control director and operations manager for the employer for four years. Employee began to notice deviations from the specifications contained the employer's standards and labels, which violated the provisions of the Connecticut Uniform Food, Drug, and Cosmetic Act (Act), Conn. Gen. Stat. § 19-222. Employee communicated in writing to the employer regarding the deviations. A few months later, his employment was terminated. Although the stated reason for his discharge was unsatisfactory performance, employee was actually dismissed in retaliation for his efforts to ensure that the employer's products complied with applicable law.


  • In reviewing the motion to strike, the court held that: 
  • (1) contracts of permanent employment or for an indefinite term were terminable at will, 
  • (2) the employee's position in the company might have exposed him to the possibility of criminal prosecution under Conn. Gen. Stat. §19-215, 
  • (3) since the appeal was before the court on a motion to strike, the court must take the facts alleged in the employee's complaint as true, 
  • (4) public policy dictated that the court recognize a tort claim for wrongful discharge.
The court found error in the order and remanded for further proceedings.

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