Yuan v. Johns Hopkins University, 157 A.3d 254

Dr. Daniel S. Yuan was a researcher at Johns Hopkins University (JHU) working on the NIH-funded SLAM project; he raised repeated internal concerns (2004–2011) that data were flawed and reported alleged research misconduct.
Yuan’s faculty/employee contract expired Dec. 31, 2011; he alleges he was effectively terminated in retaliation for reporting research misconduct and later was denied access to frozen cell lines he had collected.
Yuan filed suit (Dec. 2013) asserting: wrongful termination in violation of public policy grounded in federal research-misconduct law/regulations (42 U.S.C. § 289b; 42 C.F.R. Part 93), conversion of research materials, and related tort claims.
JHU moved to dismiss (or for summary judgment), arguing the federal research-misconduct scheme delegates investigation and remedial authority to institutions (no private damages remedy), and JHU’s policies establish institutional ownership of research materials.
Trial court and Court of Special Appeals dismissed Yuan’s wrongful-termination and conversion claims; Maryland Court of Appeals granted certiorari and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal research-misconduct statutes/regulations supply a clearly discernible Maryland public policy to support wrongful termination tort damages	Yuan: reporting violations of 42 U.S.C. § 289b and 42 C.F.R. Part 93 is protected public-policy conduct; he was retaliated against and seeks tort damages	JHU: the federal scheme defers to institutions for investigation and remedy, lacks a private damages remedy, and is too vague to define state public policy for tort relief	Court: No — the regulations create an institutional, self‑regulatory scheme not a clear, judicially manageable public policy to support wrongful discharge damages; claim dismissed
Whether JHU’s denial of access to cell lines constituted conversion	Yuan: JHU first indicated he could access materials then denied access, depriving him of property	JHU: its written Access and Retention policy vests ownership and control of research data/materials in the University (subject to limited exceptions)	Court: No conversion — as a matter of law JHU owned the materials under its policy, so it could control access; conversion claim fails

Adler v. Am. Standard Corp., 291 Md. 31 (establishing Maryland’s public-policy exception to at-will employment)
Parks v. Alpharma, Inc., 421 Md. 59 (federal regulations lacked sufficient specificity to create Maryland public policy for wrongful discharge)
Wholey v. Sears Roebuck, 370 Md. 38 (elements for wrongful discharge and limits on recognizing new public-policy mandates)
Makovi v. Sherwin–Williams Co., 316 Md. 603 (statutory remedies may preclude tort damages to vindicate same public policy)
Insignia Residential Corp. v. Ashton, 359 Md. 560 (refusal to commit illegal act as clear public-policy basis for wrongful discharge)
Darcars Motors of Silver Spring, Inc. v. Borzym, 379 Md. 249 (definition and elements of conversion)
Solomons v. United States, 137 U.S. 342 (employee-created work done within employment becomes employer property)