Normally, we discuss current cases as they can be good examples of what employers are, or are not, supposed to do.  Sometimes we discuss cases just because they have to do with employment or labor law and we just find them interesting.  In the case of Beck v. Dollinger, an employee was terminated following the report of a co-worker to his employer that the plaintiff, Beck, believed was false.

The defendant in the case, following a disagreement with Beck, her supervisor, reported that Beck had raised his voice and used expletives when addressing her.  Beck denied taking such actions.  An investigation was conducted by their employer, American Crystal, and determined that Beck “created a hostile working environment by cursing and yelling” at Dollinger.  He was terminated by American Crystal, as it was not the first complaint hostile behavior that was substantiated against Beck.  In response, Beck sued both American Crystal and Dollinger.  He alleged that Dollinger committed tortious interference with his employment contract.  After some procedural maneuvering, American Crystal was dismissed from the complaint, and Dollinger moved for summary judgment.

Minnesota recognizes tortious interference of contract claims for at-will employment.  The plaintiff must establish the following:

1. The existence of a contract;
2. The alleged wrongdoer’s knowledge of the contract;
3. Intentional procurement of its breach;
4. Without justification; and
5. Damages

The claim, thus far, has been limited to employees in supervisory roles, as opposed to co-workers with no decision-making authority.  Dollinger argued that Beck could not establish intentional procurement of Beck’s termination, as she was not involved in the decision to terminate his employment or that she intended to cause his termination.  The court found that her report ultimately did lead to his termination, so that element was satisfied.

In determining whether Dollinger intended to get Beck fired, the court looked to whether Dollinger did so with actual malice.  Beck argued that Dollinger lied about the incident, while Dollinger argued that her acts were justified.  Beck’s only argument in support of Dollinger having actual malice was that she may have lied about the triggering incident.  However, he did so without any evidence showing that Dollinger lied.  The court found that his “conclusory and self-serving statements are insufficient to withstand summary judgment.”  The court found that American Crystal’s independent investigation supported Dollinger’s version of events, and without any evidence to support his argument, his claim could not survive summary judgment.  As such, the claim was dismissed.

If this case shows us anything, it’s the importance of thorough investigations when facing claims of employee misconduct.  While it was actually the employee who was successful in this case, the employer was also protected due to its thorough investigation of the allegations against Beck.  If you, or your organization need assistance with the investigation of claims of employee misconduct, contact Wiley Reber Law, for investigations that work.