Greco v. Myers Coach Lines, Inc., 199 A.3d 426

Greco worked 15 years for Myers Coach; her duties included ensuring bus drivers were legally qualified to drive.
Driver Berardinelli had a pacemaker on April 4, 2012; he sought to resume driving on April 27 and produced a May 9, 2012 PennDOT letter suggesting eligibility.
Greco contacted PennDOT multiple times and was advised a two-month post‑surgery waiting period applied (i.e., not eligible until June 5); she relayed that to management and the driver.
Management (including David Myers and supervisor Barry Bradosky) criticized Greco; her husband, also an employee, was fired after confronting management; Greco was then terminated.
Greco sued under Pennsylvania’s Whistleblower Law and for common‑law wrongful discharge; the trial court awarded her $2,400 and attorneys’ fees.
The Superior Court vacated the judgment and remanded for entry of JNOV for Myers Coach, concluding Greco failed to prove a protected report of ‘‘wrongdoing’’ under the Whistleblower Law and failed to state a public‑policy wrongful discharge claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Greco made a protected report of "wrongdoing" under the Whistleblower Law	Greco: she reported that Myers would have illegally permitted an unqualified driver on the road; her PennDOT contacts prevented an imminent statutory violation	Myers: no actual violation occurred; Greco only clarified PennDOT guidance and did not report an employer law violation	Held: No. The report must identify an actual violation of law/regulation; here no violation occurred and Greco conceded she did not report a specific employer legal violation.
Whether Greco’s termination states a common‑law wrongful discharge in violation of public policy	Greco: she was fired for performing her safety‑related job duties and preventing a legal violation	Myers: at‑will employment; termination was lawful and non‑contrary to recognized public‑policy exceptions	Held: No. Termination for insisting on compliance did not fit the narrow public‑policy exceptions that overcome at‑will employment.

Bailets v. Pennsylvania Turnpike Comm'n, 123 A.3d 300 (Pa. 2015) (Whistleblower Law protects reports identifying violations of law or regulation)
Riggio v. Burns, 711 A.2d 497 (Pa. Super. 1998) (reports too general/vague do not constitute statutory "wrongdoing")
Sukenik v. Township of Elizabeth, 131 A.3d 550 (Pa. Commw. Ct. 2016) (report must identify law allegedly violated; objective test requires an actual violation)
United Envtl. Grp., Inc. v. GKK McKnight, LP, 176 A.3d 946 (Pa. 2017) (standards for JNOV review)
Shamnoski v. PG Energy, 858 A.2d 589 (Pa. 2004) (appellate standard: view record in light most favorable to verdict winner)
Mikhail v. Pennsylvania Org. for Women in Early Recovery, 63 A.3d 313 (Pa. Super. 2013) (limited public‑policy exceptions to at‑will employment)
Johnson v. Resources for Human Development, Inc., 789 F. Supp. 2d 595 (E.D. Pa. 2011) (report must specify how conduct is illegal; mere concerns or employer inaction insufficient)