## Facts

- George B. Geary worked for United States Steel Corporation as a tubular-products salesman from 1953 until he was discharged on July 13, 1967.
- His employment relationship was expressly at will.
- Geary believed a new high-pressure tubular casing had not been adequately tested and posed a serious safety risk to users.
- He raised concerns with supervisors; after being told to “follow directions,” he agreed but continued to object and escalated the matter to a sales vice president.
- The product was reevaluated and withdrawn from the market.
- Geary was then discharged without notice and alleged the termination was wrongful, malicious, and abusive, causing reputational harm, mental anguish, and financial loss.
- He sued in tort seeking compensatory and punitive damages.

## Issues

1. Whether an at-will employee may recover in tort for “wrongful discharge” when the employer has a plausible business reason for termination and the discharge does not violate a clear mandate of public policy.
2. Whether Pennsylvania common law should recognize a broad tort remedy for arbitrary discharge absent statutory or contractual limits.
3. Whether the complaint stated a claim under prima facie tort or any other recognized tort theory.

## Decision

- The Supreme Court of Pennsylvania affirmed dismissal of the amended complaint on demurrer.
- The court held that, in at-will employment, no cause of action lies for discharge where the pleadings disclose a plausible and legitimate reason for termination and no clear mandate of public policy is violated.
- The court declined to adopt a generalized prima facie tort theory as a basis for challenging at-will terminations.
- A dissent would have allowed Geary to attempt to prove arbitrary and retaliatory discharge based on public safety concerns.

## Legal Principles

- In Pennsylvania, an at-will employment relationship may be terminated by either party for any reason or no reason, absent contractual or statutory restriction.
- A narrow public-policy limitation may apply only when a discharge clearly violates a mandate of public policy.
- A complaint that reveals a plausible business justification for termination undermines a wrongful-discharge tort claim in the at-will setting.
- Courts will not create a broad, generalized “prima facie tort” remedy to convert at-will employment into judicial review of routine personnel decisions.

## Conclusion

The court refused to recognize a broad tort of wrongful discharge for an at-will employee and held that, without a clear public-policy violation and where a plausible business reason appears on the pleadings, the employee has no tort remedy for termination.


Geary v. U.S. Steel Corp., 456 Pa. 171, 319 A.2d 174 (Pa. 1974)