Alvin Hoff v. Wiley Rein, LLP, 110 A.3d 561

Hoff was an at-will Records Coordinator at Wiley Rein who drafted employee performance evaluations and reported to Douglas Smith.
The firm’s Director of Operations, Derek McCleskey, directed Hoff and Smith to give colleague Gloria Ward an "unsatisfactory" evaluation and place her on a performance improvement plan (PIP).
Smith pressured Hoff to instead issue a "satisfactory" evaluation; Hoff refused and ultimately prepared the unsatisfactory evaluation as McCleskey requested.
McCleskey then fired Hoff, reportedly because HR had documents indicating Hoff accepted loans from Ward; Hoff denied the loans and sued.
Hoff sued for wrongful termination under the Adams public-policy exception (refusal to commit a crime) and for retaliatory discharge under the DCHRA; the trial court dismissed both counts and Hoff appealed the Adams claim.
The appellate court limited review to the Adams claim (DCHRA claim waived) and affirmed the dismissal, holding Hoff failed to allege he was required to violate the criminal statute cited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hoff stated an Adams wrongful-discharge claim (refusal to violate law)	Hoff contends he was forced to falsify Ward's evaluation, which would violate D.C. criminal fraud for false promises about future performance	Wiley Rein argued Hoff did not plead facts showing he was required to commit the crime alleged or that the evaluation would constitute a false promise as to future performance	Held: Dismissed — Hoff was not put to a choice to violate §22‑3221(c); the evaluation referenced past performance and any implication about future performance was mere prediction, not the criminal promissory fraud alleged

Adams v. George W. Cochran & Co., 597 A.2d 28 (D.C. 1991) (recognizes narrow public-policy exception to at-will employment where employee is discharged for refusing to violate the law)
Hillbroom v. PricewaterhouseCoopers LLP, 17 A.3d 566 (D.C. 2011) (standard of review for dismissal and accepting complaint allegations as true)
Virginia Acad. of Clinical Psychologists v. Grp. Hosp. & Med. Servs., 878 A.2d 1226 (D.C. 2005) (civil fraud principles regarding promissory representations inform interpretation of criminal §22‑3221(c))
Bennett v. Kiggins, 377 A.2d 57 (D.C. 1977) (promissory fraud requires positive statement of intent to perform; predictions or hopes are not actionable)
Peoples Drug Stores v. District of Columbia, 470 A.2d 751 (D.C. 1983) (statutory construction principle: look to statutory language for legislative intent)