134 Conn. App. 134
Conn. App. Ct.2012Background
- Plaintiff Stephanie Armshaw was an at-will emergency room nurse employed by Greenwich Hospital.
- She had prior disciplinary action, including a two-day suspension for conduct and insubordination.
- She was warned that another disciplinary incident would result in termination.
- On May 28, 2008, after the shift began, Armshaw failed to take a patient report during a myocardial infarction case.
- Her employment was terminated that same day for alleged conduct and quality-of-work violations related to the incident.
- She sued for wrongful discharge, and the trial court granted summary judgment for Greenwich Hospital.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether discharge violated public policy | Armshaw discharged in contravention of public policy | No explicit statutory/constitutional/public policy violation shown | No public policy violation; summary judgment proper |
Key Cases Cited
- Schilberg Integrated Metals Corp. v. Continental Casualty Co., 263 Conn. 245 (2003) (summary judgment standard and review)
- Thibodeau v. Design Group One Architects, LLC, 260 Conn. 691 (2002) (at-will employment with public policy exception)
- Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471 (1980) (public policy wrongful discharge doctrine)
- Morris v. Hartford Courant Co., 200 Conn. 676 (1986) (false but negligent accusation not demonstrably improper discharge)