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tort

tortplaintiff

Related Cases

Palmateer v. International Harvester Co., 85 Ill.2d 124, 421 N.E.2d 876, 52 Ill.Dec. 13, 115 L.R.R.M. (BNA) 4165

Facts

Ray Palmateer worked for International Harvester Company for 16 years and was promoted to a managerial position. He was discharged after he reported to local law enforcement that a fellow employee might be violating the criminal code and agreed to assist in the investigation. Palmateer filed a four-count complaint against the company, alleging retaliatory discharge among other claims. The Circuit Court dismissed the complaint, stating it failed to state a cause of action, and the Appellate Court affirmed this decision.

The plaintiff, Ray Palmateer, complains of his discharge by International Harvester Company (IH). He had worked for IH for 16 years, rising from a unionized job at an hourly rate to a managerial position on a fixed salary. Following his discharge, Palmateer filed a four-count complaint against IH, alleging in count II that he had suffered a retaliatory discharge.

Issue

Did Palmateer state a valid cause of action for retaliatory discharge when he was fired for reporting potential criminal activity to law enforcement?

Rule

The tort of retaliatory discharge exists to protect employees from being fired for actions that contravene public policy, such as reporting criminal activity.

Analysis

The Supreme Court analyzed whether Palmateer's allegations constituted a violation of public policy. The court noted that public policy favors the reporting of crime and that Palmateer's actions in reporting potential criminal activity and agreeing to assist law enforcement were protected under this policy. The court emphasized that the employer's business judgment could not override the public policy established by the legislature regarding the reporting of crimes.

The foundation of the tort of retaliatory discharge lies in the protection of public policy, and there is a clear public policy favoring investigation and prosecution of criminal offenses. Palmateer has stated a cause of action for retaliatory discharge.

Conclusion

The Supreme Court concluded that Palmateer had stated a cause of action for retaliatory discharge, reversing the lower court's dismissal of his complaint and remanding the case for further proceedings.

The cause of action expressed in count II of Palmateer's complaint was improperly dismissed, and the cause should be returned to the circuit court for further proceedings.

Who won?

Ray Palmateer prevailed in part, as the Supreme Court recognized his right to bring a claim for retaliatory discharge based on public policy.

Underwood, J., filed a dissenting statement.

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