Haun v. Community Health Systems, Inc.
14 A.3d 120
| Pa. Super. Ct. | 2011Background
- Haun was CFO of Phoenixville Hospital from June 2007 to November 12, 2008.
- Haun's newborn twins were injured during hospitalization; Drake Haun sustained severe CNS injury after an IV disconnect in the NICU.
- Haun and Theresa Haun sued Phoenixville Hospital, Phoenixville LLC, and several doctors for medical malpractice.
- Five days after service of process, Phoenixville defendants discussed terminating Haun, culminating in his termination on November 12, 2008 for being an “adversary” to the company.
- Haun sued for (1) wrongful termination in violation of public policy, (2) specific intent exception to the at-will doctrine, and (3) tortious interference with other contracts; defendants filed preliminary objections.
- Trial court partially sustained and partially overruled the objections; Superior Court affirmed in part and reversed in part, remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Public policy wrongful discharge sufficiency | Haun alleged his termination violated public policy. | Defendants argued no recognized public policy exception. | Overruled (demurrer to Count I) |
| Public policy identification of clear mandate | Haun alleged a clear Pennsylvania public policy against retaliation. | No identifiable mandated policy was pleaded. | Overruled (demurrer to Count I) |
| Tortious interference with at-will employment | Haun claimed interference with contractual relations in employment. | At-will employees cannot maintain interference claim; must involve prospective relations. | Sustained; Count III demurrer upheld; at-will interference not cognizable |
Key Cases Cited
- Hennessy v. Santiago, 708 A.2d 1269 (Pa. Super. 1998) (interference with at-will employment requires prospective relation, not present at-will contract)
- Curran v. Children's Service Center, 578 A.2d 8 (Pa. Super. 1990) (at-will employee may have interference claim when related to prospective relations)
- Yaindl v. Ingersoll-Rand Co., 422 A.2d 611 (Pa. Super. 1980) (speech on interference with prospective contractual relations; dicta cited by majority)
- Thompson Coal Co. v. Pike Coal Co., 412 A.2d 466 (Pa. 1979) (Restatement § 766 influence on at-will contracts (Comment g))
- In re Estate of Stephano, 981 A.2d 138 (Pa. 2009) (jurisprudential considerations on appellate precedents)