Haddle v. Garrison,
525 U.S. 121 (1998)

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No. 97-1472. Argued November 10, 1998-Decided December 14, 1998 Petitioner, an at-will employee, filed this action for damages against respondents alleging, inter alia, that they conspired to have him fired in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at their upcoming criminal trial for Medicare fraud, and that their acts had "injured [him] in his person or property" in violation of 42 U. S. C. § 1985(2). In dismissing the suit for failure to state a claim, the District Court relied on Circuit precedent holding that an at-will employee discharged pursuant to a conspiracy proscribed by § 1985(2) has suffered no actual injury because he has no constitutionally protected interest in continued employment. The Eleventh Circuit affirmed.

Held: The sort of the harm alleged by petitioner-essentially third-party interference with at-will employment relationships-states a claim for damages under § 1985(2). In relevant part, the statute proscribes conspiracies to "deter, by force, intimidation, or threat, any ... witness in any [federal] court ... from attending such court, or from testifying to any matter pending therein, ... or to injure [him] in his person or property on account of his having so attended or testified," § 1985(2), and provides that if conspirators "do ... any act in furtherance of ... such conspiracy, whereby another is injured in his person or property, ... the party so injured ... may" recover damages, § 1985(3). The Eleventh Circuit erred in concluding that petitioner must suffer an injury to a "constitutionally protected property interest" to state a claim. Nothing in the language or purpose of the proscriptions in the first clause of § 1985(2), nor in its attendant remedial provisions, establishes such a requirement. The gist of the wrong at which § 1985(2) is directed is not deprivation of property, but intimidation or retaliation against witnesses in federal-court proceedings. The terms "injured in his person or property" define the harm that the victim may suffer as a result of the conspiracy to intimidate or retaliate. Thus, the fact that employment at will is not "property" for purposes of the Due Process Clause, see Bishop v. Wood, 426 U. S. 341, 345-347, does not mean that loss of at-will employment may not "injur[e] [petitioner] in his person or property" for § 1985(2)'s purposes. Such harm has long been, and remains, a compensable injury under tort law, and there is no reason to


ignore this tradition here. To the extent that the terms "injured in his person or property" refer to such tort principles, there is ample support for the Court's holding. pp. 124-127.

132 F.3d 46, reversed and remanded.

REHNQUIST, C. J., delivered the opinion for a unanimous Court.

Charles C. Stebbins III argued the cause and filed briefs for petitioner.

Matthew D. Roberts argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Waxman, Acting Assistant Attorney General Lee, Deputy Solicitor General Underwood, David K. Flynn, and Timothy J. Moran.

Phillip A. Bradley argued the cause for respondents.

With him on the briefs for respondents Garrison et al. were Barry J. Armstrong and David E. Hudson. J. Patrick Claiborne and Terrance P. Leiden filed a brief for respondent Molloy. *

CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.

Petitioner Michael A. Haddle, an at-will employee, alleges that respondents conspired to have him fired from his job in retaliation for obeying a federal grand jury subpoena and to deter him from testifying at a federal criminal trial. We hold that such interference with at-will employment may give rise to a claim for damages under the Civil Rights Act of 1871, Rev. Stat. § 1980, 42 U. S. C. § 1985(2).

According to petitioner's complaint, a federal grand jury indictment in March 1995 charged petitioner's employer,

*Briefs of amici curiae urging reversal were filed for the Lawyers' Committee for Civil Rights Under Law by George W Jones, Jr., Jacqueline Gerson Cooper, Daniel F. Kolb, Norman Redlich, Barbara R. Arnwine, Thomas J. Henderson, Richard T. Seymour, and Teresa A. Ferrante; for the National Employment Lawyers Association et al. by Mark Allen Kleiman and Paula A. Brantner; and for the National Whistleblower Center by Stephen M. Kohn.

Full Text of Opinion

Primary Holding

No harm to a constitutionally protected property interest is required to trigger the application of a Civil Rights Act claim under Section 1985(2).


A federal grand jury indicted Healthmaster and two of its officers, Garrison and Kelly. After assisting with the investigation, an employer of Healthmaster named Haddle was scheduled to appear as a witness at the criminal trial. However, the defendants conspired with other employees of Healthmaster to retaliate against Haddle by firing him. His ensuing claim in federal court relied on Section 1985 of the Civil Rights Act. Healthmaster and the other defendants argued that his complaint should be dismissed for failing to state a claim.

Since Section 1985 requires an actual injury, the district court held that the complaint should be dismissed because it had been brought by an at-will employee, which meant that there was no actual injury. When the Eleventh Circuit affirmed the dismissal, its ruling clashed with the holdings in two other circuits.



  • William Hubbs Rehnquist (Author)
  • John Paul Stevens
  • Sandra Day O'Connor
  • Antonin Scalia
  • Anthony M. Kennedy
  • David H. Souter
  • Ruth Bader Ginsburg
  • Stephen G. Breyer
  • Clarence Thomas

Under Section 1985(2) of the Civil Rights Act, one or more parties are prohibited from conspiring to deter, intimidate, or threaten someone who is scheduled to participate in a federal court proceeding. There is no requirement in the language of the statute or related provisions that expressly bases relief on an actual injury to the plaintiff's property interests. Harm still may arise from the loss of at-will employment, which has been the proper subject of tort claims under the common law, parallel to intentional interference with contractual relations.

Case Commentary

This outcome opened the door for a potentially significant expansion in whistleblower litigation in federal court, since few cases had addressed the topic before then.

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