Pfeifer v. Federal Express Corp.
297 Kan. 547
| Kan. | 2013Background
- Pfeifer filed a diversity action against FedEx for retaliatory discharge under Kansas Workers Compensation Act rights; he sued 15 months after termination, while Kansas allows a 2-year limit.
- FedEx contract required bringing claims within law or 6 months; the district court granted summary judgment.
- Termination occurred May 2, 2008; Pfeifer filed within 2-year statutory period but outside the 6-month contract window.
- The Tenth Circuit posed two certified questions about contractual shortening of limitation periods and public policy.
- Kansas public policy protecting injured workers from retaliation under the Workers Compensation Act is a central consideration in the timing of such claims.
- The court concluded the contract shortens the 2-year statute in this retaliatory-discharge context and is invalid; the second question regarding reasonableness of 6 months was not reached.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can private contracts shorten statute of limitations for retaliatory discharge claims under Kansas law? | Pfeifer argues contract undermines public policy protecting statutory rights. | FedEx argues 60-501 allows contract modification of limitations. | Contract provision void to the extent it shortens the 2-year period. |
| If shortening is allowed, is 6 months reasonable? | Not necessary to address if contract void. | Shortening could be reasonable in other contexts. | Not reached/necessary because contract invalid. |
Key Cases Cited
- Gifford v. Saunders, 207 Kan. 360 ((1971)) (statutory limitations; general rule not directly controlling contracts shortening time)
- Hunter v. American Rentals, 189 Kan. 615 ((1962)) (public policy against waivers; contract cannot defeat statutory duty)
- Hysten v. Burlington Northern Santa Fe Ry. Co., 277 Kan. 551 ((2004)) (public policy to protect workers exercising statutory rights)
- Coleman v. Safeway Stores, Inc., 242 Kan. 804 ((1988)) (public policy against retaliation for work-related injuries; statutory rights protection)
- Murphy v. City of Topeka, 6 Kan. App. 2d 488 ((1981)) (retaliatory discharge recognized under Kansas common law)