Haddle v. Garrison (1997) Case Brief Summary | Law Case Explained

Get more case briefs explained with Quimbee. Quimbee has over 45,900 case briefs (and counting) keyed to 984 casebooks ► www.quimbee.com/case-briefs-o...
Haddle v. Garrison, Unpublished Opinion, Docket No. 96-8856 (1997)
In Haddle versus Garrison, we’ll see whether a court may dismiss a plaintiff’s complaint for failure to state a claim if prior case precedent foreclosed the plaintiff’s claim.
Michael Haddle was an at-will employee at Healthmaster Home Health Care. In March of 1995, a federal grand jury charged Healthmaster and Healthmaster officer Jeanette Garrison with Medicare fraud. Haddle cooperated in the fraud investigation and agreed to testify against Healthmaster and Garrison. Before Haddle was set to testify, Healthmaster fired Haddle.
Haddle sued Garrison and Healthmaster in the United States District Court for the Southern District of Georgia. Haddle claimed that Healthmaster retaliated against him by firing him after he agreed to be a witness at the fraud trial. Haddle sought relief under Section 1985 2 of 42 U.S.C., which holds that parties can’t conspire to deter a person from testifying or retaliate against a person who testifies in a trial. Section 1985 requires that the person bringing the claim suffered an injury in his person or property as a result of the conspiracy to prevent the person from testifying. Garrison moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The district court turned to precedent from Morast versus Lance, in which the United States Court of Appeals for the Eleventh Circuit held that an at-will employee doesn’t have a constitutionally protected interest in his or her continued employment. This means that if an at-will employee is fired, his or her loss of employment isn’t an actual injury under Section 1985. Because Haddle was an at-will employee, his loss of employment wasn’t actual injury under Section 1985. Therefore, Haddle failed to state a claim, and the district court granted Garrison’s motion to dismiss. Haddle appealed to the Eleventh Circuit.
Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: www.quimbee.com/cases/haddle-...
The Quimbee App features over 45,900 case briefs keyed to 984 casebooks. Try it free for 7 days! ► www.quimbee.com/case-briefs-o...
Have Questions about this Case? Submit your questions and get answers from a real attorney here: www.quimbee.com/cases/haddle-...
Did we just become best friends? Stay connected to Quimbee here:
Subscribe to our RUclips Channel ► ruclips.net/user/subscription_...
Quimbee Case Brief App ► www.quimbee.com/case-briefs-o...
Facebook ► / quimbeedotcom
Twitter ► / quimbeedotcom
#casebriefs #lawcases #casesummaries