Haddle v.

Garrison
Facts: Haddle worked for Healthmaster Home Health Care as an at-will employee.
He filed a case against his former employer and Garrison (defendant), a
Healthmaster officer, alleging that he was illegally fired to avoid his participation
in a criminal proceeding as a witness. The defendants filed a motion to dismiss the
plaintiff's claim for failure to provide a basis for relief. The court decided that the
statute under which he sought relief, 42 U.S.C. 1985(2), prohibited remedies for an
at-will employee, and granted the defendant's motion to dismiss. Haddle filed an
appeal with the court of appeals, which upheld the decision of the lower court. The
United States Supreme Court granted certiorari.

Issue: The question, in this case, was whether the Civil Rights claim under Section
1985 (2) requires a violation of a constitutionally protected property right to apply.

Rule: The heart of the offense addressed by 42 U.S.C.S. 1985(2) is not the loss of
property, but rather the intimidation or retaliation of witnesses in federal court
proceedings. The word "damaged in his person or property" expresses the harm
that a victim may experience as a result of an intimidation or retaliation plot.
Therefore, the fact that employment at will is not considered "property" for the
purposes of the Due Process Clause does not indicate that the loss of employment
at will cannot cause harm to the petitioner's person or property under 42 U.S.C.S.
1985. (2).

Application: This answer to the question of this case is no.

It is not essential that a constitutionally protected property right or interest be
violated in order to file a Section 1985 claim under the Civil Rights Act (2). The
clause indicates that it is a crime for one or more individuals to conspire to hinder,
intimidate, or threaten another individual from attending and testifying during a
federal court trial. The Eleventh Circuit was of the conclusion that Haddle (P) had
suffered no harm since he had lost no compensable property interest as a result of
the termination of his at-will employment. This interpretation cannot be
incorporated into the relevant section or its corrective measures. Instead of material
damage, this provision addresses intimidation and retaliation against witnesses. In
this scenario, such conduct is permissible since, under tort law, the loss of
employment at-will is a compensable damage, much like breach of contract.
Consequently, Haddle's claim should not have been rejected on the basis that he
failed to establish a claim. Case was remanded after the judgement was overturned.

Conclusion: Under 42 U.S.C. 1985, the kind of harm described by the petitioner,
essentially third-party interference with at-will employment relationships, created a
cause for remedy. (2). Despite the fact that his employment contract was at-will, he
held extensive contract rights. The fact that employment at will is not considered
"property" for purposes of the Due Process Clause does not entail that the loss of
employment at will cannot "injure [petitioner] in his person or property" for
purposes of section 1985. (2). This kind of loss has been and is a compensable
injury under tort law, and there is no reason to depart from this precedent in this
instance. Insofar as the expression "damaged in his person or property"
corresponds to such tort principles, there is substantial support for the Court's
ruling.

Synthesis: The word "employment-at-will" is unclear, and at the time of this case,
just a handful of Supreme Court cases had addressed this problem. In this action,
the National Whistleblowers Association provided amicus, or unrequested
testimony and legal advice. The Supreme Court's decision to overturn this verdict
may have led to an increase in comparable federal court cases.