## Facts

- Michael A. Haddle worked as an at-will employee for Healthmaster, Inc.
- A federal grand jury indicted Healthmaster and two of its officers, Robert Garrison and Jack Kelly, for Medicare fraud.
- Haddle provided information during the grand jury investigation and was expected to testify at the criminal trial.
- Haddle alleged Garrison and Kelly conspired with other Healthmaster officers to have him fired.
- He claimed the firing was intended to retaliate for complying with a grand jury subpoena and to deter him from testifying.
- Haddle sued for damages under 42 U.S.C. § 1985(2), alleging he was injured “in his person or property” by the conspiracy.

## Issues

1. Whether termination of an at-will employee, allegedly in retaliation for cooperation with federal proceedings or to deter testimony, constitutes an injury “in his person or property” under 42 U.S.C. § 1985(2).
2. Whether a § 1985(2) damages claim requires injury to a “constitutionally protected property interest” in continued employment.

## Decision

- The Supreme Court unanimously reversed the Eleventh Circuit and remanded.
- The Court held that the alleged harm—third-party interference with an at-will employment relationship—states a damages claim under § 1985(2).
- The Court rejected the rule that a plaintiff must show injury to a constitutionally protected property interest to plead “injur[y] in his person or property” under § 1985(2).

## Legal Principles

- The first clause of § 1985(2) targets conspiracies to deter federal-court witnesses from attending or testifying, or to injure them for doing so; the statute’s focus is witness intimidation and retaliation.
- “Injured in his person or property” in § 1985(2) and the remedial provision in § 1985(3) describes the type of harm from the conspiracy and does not import a constitutional-property prerequisite.
- The absence of a due-process “property” interest in at-will employment does not bar statutory injury under § 1985(2).
- Retaliatory interference with at-will employment is a recognized compensable harm in tort law and can qualify as injury for § 1985(2) purposes.

## Conclusion

The Court held that an at-will employee who is fired as part of a conspiracy to retaliate for, or deter, federal testimony can plead injury “in his person or property” under § 1985(2) even without a constitutionally protected property interest in continued employment.


Haddle v. Garrison, 525 U.S. 121 (1998)