FindLaw > Criminal Law Summaries > 1998 Index > Haddle v. Garrison

Case: Haddle v. Garrison

Issue: Whether a person is "injured in his property or person" when a third-party induces the person's employer to terminate his at-will employment as part of a conspiracy prohibited by 42 U.S.C. §1985(2). Specifically, can a person state a claim for damages by alleging that a conspiracy proscribed by §1985(2) induced his employer to terminate his at-will employment?

Facts: Petitioner Michael Haddle cooperated with federal agents in an investigation that lead to the indictment of his employer, Healthmaster, Inc. and respondents Jeanette Garrison and Dennis Kelly for Medicare fraud. Haddle was subpoenaed to testify before the grand jury, and although he did appear, he did not testify due to time constraints. Additionally, Haddle was expected to appear as a witness in the criminal trial resulting from the indictment. Garrison and Kelly subsequently conspired with a remaining Healthmaster officer to have Haddle fired, both in retaliation for assisting with the federal proceedings, and also to intimidate him.

Haddle sued for damages under 42 U.S.C. §1985(2) (which prohibits conspiracies to "deter, by force, intimidation, or threat, any party or witness in any Court of the United States from attending such court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure such party or witness in his person or property on account of his having so attended or testified") alleging a conspiracy to intimidate him from testifying in the upcoming criminal trial, and a conspiracy to retaliate against him for appearing before the grand jury. Garrison and Kelly moved to dismiss for failure to state a claim upon which relief can be granted because §1985 requires that complainants allege an injury in their person or property in order to recover damages. Under the authority of an earlier case, the Eleventh Circuit accepted respondents' argument that since Haddle was an at-will employee, he had no constitutionally protected interest in continued employment, and therefore could not allege an injury. The Supreme Court granted certiorari to resolve a conflict in the Circuits.

Holding: As required by §1985(2) in order to state a claim for damages, a person is "injured in his property or person" when others conspire to have him terminated from at-will employment because such action violates principles of tort law. Allegations of third-party interference with at-will employment are sufficient to state a claim for relief under §1985(2) even though such employment is not a constitutionally protected property right.

Reasoning: Writing for a unanimous Court, Justice Rehnquist rejected the Eleventh Circuit's position that there must be injury to a "constitutionally protected property interest" to state a claim for damages under §1985. Section 1985 is intended to redress intimidation or retaliation against witnesses in federal court proceedings. Limiting causes of action under the statute to restoration of property misses the point and improperly limits the statute's effect. Instead, the Court analyzed "injured in his person or property" through the lens of tort-law, which recognizes third party interference with at-will employment as a breed of the traditional tort of intentional interference with contractual relations and intentional interference with prospective contractual relations.

Other Opinions: None.

Comment: This opinion provides a potential weapon to witnesses and potential witnesses in long term white-collar investigations who are intimidated by their employers. White-collar targets often try to subtly and not so subtly intimidate employees and former employees in order to keep them from cooperating with the United States. The prospect of money damages for intimidated witnesses, who will no doubt be informed of the Court's opinion by prosecutors, may well lessen the trepidation felt by such individuals. That intimidating conduct can be violative of a civil rights statute also opens up Fed. R. Evid. 404(b) opportunities for enterprising prosecutors. Defense counsel should take special care to advise the target against conduct that could be interpreted as intimidating.