Sheets v. Teddy’s Frosted Foods Inc.
179 Conn. 471, 427 A.2d 385 (Conn. 1980)

  • Sheets worked for Teddy’s Frosted Foods. He began to notice that the company was producing substandard foods and was violating labeling laws.
    • When he mentioned his concerns to management, they fired him.
  • Sheets felt that he was wrongfully discharged, and sued.
    • Sheets argued three things; that there was an implied contract, that it was a violation of public policy to fire someone for ensuring food safety, and that it was a malicious discharge.
    • Sheets admitted that his employment contract said he could be terminated at-will, but that he argued that couldn’t be fired for something that violates public policy. To do so is a tort.
  • The Trial Court found for Teddy’s and dismissed the case. Sheets appealed.
    • The Trial Court found that Sheet’s employment contract said he could be fired at will, so Teddy didn’t violate any of Sheet’s contractual rights.
  • The Connecticut Supreme Court reversed and remanded for trial.
    • The Connecticut Supreme Court found that the Trial Court erred when they only considered the case from the breach of contract perspective.
    • The Court found that the tort claim was sufficient to remand the case for trial.
    • The Court recognized an exception to the traditional rules governing employment-at-will so as to permit cause of action for wrongful discharge where the discharge contravenes a clear mandate of public policy.
      • The Court noted that claims involving mandates of public policy are actionable, ordinary disputes between employees and employers are not.
      • Sheets’ job as quality control supervisor exposed him to possible liability and criminal prosecution if he helped cover up the violations.
      • Since Sheets was forced to choose between possibly going to jail and staying employed, he had a case, and should get a trial.
  • In a dissent it was argued that this decision gave the employees the ability to coerce employers into not firing them.
    • The dissent argued that this decision invited the unrestricted use of an allegation of almost any statutory or even regulatory violation by an employer as the basis for cause of action by a discharged employee.
    • The dissent argued that the Connecticut Legislature had considered Whistleblower laws, but had not enacted any (as of the date of this trial). Therefore, who were the Courts to create laws that the legislature had failed to enact?
  • There are plenty of statutory categories (race, age, gender) that would override an employment at-will contract. Sheets didn’t have a particular statute he could point to that put him in a protected category. However, the fact that protected categories existed makes it possible to accept Sheets’ argument.
  • In theory, if this case had gone the other way, other people in Sheets’ position would not report violations of health codes, and the State has an interest in wanting people to report health violations.