## Facts

- Franklin C. Baldwin worked for Dorr Woolen Company from November 1952 until his discharge in March 1975, at age 50.
- The company terminated Baldwin for asserted “economic necessity.”
- Baldwin had vested retirement benefits, but he could not receive them until age 55.
- Baldwin had employer-provided group term life insurance for $36,000, which he could continue after discharge if he paid the premiums.
- Baldwin did not continue the policy after termination, allegedly because he could not afford the premiums.
- Baldwin died one year after discharge at age 51; his widow was the named beneficiary.
- The estate administrator and the widow sued for wrongful discharge, seeking damages primarily equal to the policy amount.
- The estate alleged Baldwin was discharged due to age, a heart condition (angina), and to prevent receipt of retirement benefits, characterizing the termination as bad faith under New Hampshire’s wrongful-discharge doctrine.

## Issues

1. Whether the estate stated a viable wrongful-discharge claim based on alleged bad-faith termination and could recover damages measured by the amount of lapsed group life insurance.
2. Whether the widow, as the named beneficiary, could recover the life insurance proceeds as damages for the alleged wrongful discharge that preceded the lapse of coverage.

## Decision

- The court held that neither the estate nor the widow was entitled to the claimed damages, including the value of the group term life insurance policy.
- The court dismissed the appeal, leaving the defendant prevailing on the dispositive rulings below.

## Legal Principles

- A bad-faith termination of an at-will employee may constitute a breach of the employment contract, but recoverable damages must be legally cognizable and tied to the employment relationship and the breach.
- Wrongful-discharge claims and related contract-based remedies are generally personal to the employee; derivative claims by nonemployees require an independent legal basis.
- When an employee may continue group life insurance after termination by paying premiums, the employer is not liable in wrongful discharge for the face amount of coverage that lapsed because the employee did not maintain the policy.

## Conclusion

The court refused to treat the face value of lapsed, post-termination group life insurance as recoverable wrongful-discharge damages and rejected both the estate’s and the beneficiary’s attempts to recover those proceeds from the employer.


Howard v. Dorr Woolen Co., 120 N.H. 295 (N.H. 1980)