## Facts

- Ray Palmateer worked for International Harvester for approximately 16 years, advancing from an hourly union job to a salaried managerial position.
- Palmateer alleged he informed local law enforcement that a co-employee might have violated the Illinois Criminal Code and agreed to assist the investigation and testify if requested.
- After the employer learned of his cooperation with law enforcement, it terminated his employment.
- Palmateer filed a multi-count complaint that included a tort claim for retaliatory discharge, alleging he was fired for conduct supported by Illinois public policy favoring reporting and prosecution of crimes.
- The circuit court dismissed the retaliatory discharge count for failure to state a claim, and the appellate court affirmed in a divided opinion.

## Issues

1. Whether an at-will employee states a claim for retaliatory discharge when alleged to have been fired for reporting suspected criminal conduct by a co-employee and agreeing to cooperate with law enforcement.
2. Whether Illinois public policy, as reflected in criminal statutes, can support a retaliatory-discharge tort claim outside the workers’ compensation setting.
3. Whether the complaint’s allegations were sufficiently specific to survive dismissal at the pleading stage.

## Decision

- The Illinois Supreme Court reversed the dismissal of the retaliatory discharge count and remanded for further proceedings.
- The court held the complaint alleged a discharge in retaliation for conduct that Illinois public policy encourages: reporting suspected violations of the criminal law and assisting law enforcement.
- The court rejected the employer’s arguments that the suspected offense was too minor to implicate public policy and that a formal adversarial relationship between employee and employer was required.
- The court found the pleadings adequate at the motion-to-dismiss stage; the employer could have sought a more definite statement if needed.

## Legal Principles

- Illinois recognizes a narrow public-policy exception to employment at will through the tort of retaliatory discharge.
- A retaliatory discharge claim requires allegations that (1) the discharge was retaliatory and (2) the discharge contravened a clearly mandated Illinois public policy.
- The tort protects public policy interests grounded in constitutional and statutory sources, not an employee’s private interests or generalized fairness.
- Public policy favoring effective law enforcement supports protection for employees discharged for providing information to police and cooperating in investigations and prosecutions.
- The seriousness of the suspected crime does not control the public-policy analysis once the legislature has criminalized the conduct.

## Conclusion

The court held that an at-will employee may pursue a retaliatory-discharge claim when allegedly fired for reporting suspected criminal activity and cooperating with law enforcement, because such retaliation conflicts with clearly mandated Illinois public policy favoring enforcement of the criminal laws.


Palmateer v. International Harvester Co., 85 Ill. 2d 124, 421 N.E.2d 876 (Ill. 1981)