## Facts

- Michael J. Edmondson worked for Shearer Lumber Products at its Elk City mill for 22 years and later became a salaried employee with a strong performance review.
- Edmondson was widely known for civic involvement and attendance at public meetings on matters of public concern.
- In early 2000, Edmondson attended meetings of a community group, “Save Elk City,” regarding a proposal to a federal working group on management of the Nez Perce National Forest; Edmondson learned the proposal was tied to Shearer’s owner.
- Edmondson did not publicly speak at the group meetings and did not discuss his opinions about the proposal at work.
- Shearer management believed Edmondson opposed the employer-supported proposal and that he had attended task force meetings and contacted individuals involved with the federal working group.
- Edmondson claimed management intimidated him and warned him not to form or express opinions to the federal working group contrary to Shearer’s interests.
- On February 15, 2000, Shearer terminated Edmondson, stating it was due to his “continued involvement in activities” harmful to the company’s long-term interests.
- Edmondson sued, alleging wrongful discharge in violation of Idaho public policy protecting citizen participation in political and civic matters.

## Issues

1. Whether terminating an at-will employee for alleged opposition to an employer-backed public-lands proposal and related contacts with a governmental task force falls within Idaho’s public-policy exception to at-will employment.
2. Whether Edmondson identified a clear mandate of Idaho public policy, rooted in constitutional or statutory authority, that would be violated by such a termination.

## Decision

- The Idaho Supreme Court affirmed summary judgment for Shearer.
- Even assuming Edmondson was fired because of his stance on the proposal and his contacts with the governmental task force, he failed to identify a clearly expressed Idaho public policy that made the discharge actionable.
- The court declined to broaden the public-policy exception to cover generalized political activity protections against a private employer absent a specific legal source.

## Legal Principles

- Idaho follows the at-will employment rule, subject to a narrow public-policy exception.
- A wrongful-discharge claim under the public-policy exception requires a “clear mandate” of public policy, typically found in a constitutional provision, statute, or regulation carrying the force of law.
- General appeals to civic participation or free expression, without a specific legal provision that the discharge would contravene, are insufficient to create tort liability for a private employer.
- On summary judgment, assumed facts do not create liability where the asserted public policy is not clearly defined in controlling law.

## Conclusion

The court held that Edmondson’s allegations of termination for opposing an employer-supported public-lands proposal did not fit Idaho’s narrow public-policy exception because he identified no specific constitutional, statutory, or regulatory mandate that the discharge violated; summary judgment for the employer was affirmed.


Edmondson v. Shearer Lumber Prods., 139 Idaho 172, 75 P.3d 733 (Idaho 2003)