Holden v. University System of Maryland
112 A.3d 1100
Md. Ct. Spec. App.2015Background
- Paula Holden, an at‑will employee funded by Title III grants, was Coordinator of Graduate Admissions at UMES and was told her job required recruiting graduate students.
- Holden refused to perform recruitment she believed Title III funds prohibited and filed an internal grievance and exchanged emails with HR and the Attorney General’s office.
- UMES later adjusted funding for her position and placed Holden on administrative leave; she was terminated without cause after a year.
- Holden sued UMES, USM (later dismissed), and her supervisor Dr. Keane‑Dawes for wrongful termination, alleging she was fired for refusing to use Title III funds for recruitment.
- The circuit court granted defendants’ motion to dismiss for failure to allege a violation of a clear mandate of public policy; the Court of Special Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Holden’s discharge violated a “clear mandate of public policy” because Title III prohibits using funds for recruitment | Holden: Title III does not list recruitment among authorized uses and defendants believed recruitment was prohibited, so termination violated public policy | Defendants: Title III’s prohibitions do not expressly bar recruitment; no statutory/regulatory language creates a clear public‑policy mandate | Court: No — Title III contains no express prohibition on recruitment; Holden failed to plead a clear mandate of public policy |
| Whether an employer’s or employee’s reasonable but mistaken belief that conduct is unlawful can support wrongful discharge | Holden: Even if Title III is ambiguous, defendants’ belief that recruitment was prohibited should support her claim | Defendants: Public‑policy exception is narrow; liability requires that the employer’s conduct actually violate law, not just a reasonable belief | Court: No — courts will not extend the exception based solely on reasonable (but incorrect) beliefs about legality; requires an actual statutory, constitutional, or judicial declaration of public policy |
Key Cases Cited
- Wholey v. Sears, Roebuck & Co., 139 Md. App. 642 (Md. Ct. Spec. App.) (describing the narrow public‑policy exception to at‑will employment)
- Adler v. American Standard Corp., 830 F.2d 1303 (4th Cir. 1987) (applying Maryland law and refusing to expand wrongful‑discharge claims based on a mistaken belief about unlawful conduct)
- Clark v. Modern Group, 9 F.3d 321 (3d Cir. 1993) (refusing to create a wrongful‑discharge cause where only a reasonable belief, not an actual illegality, is alleged)