## Facts

- Theodore (“Ted”) Rothrock managed the body shop at an auto dealership owned and run by his brother, Bruce Rothrock; Ted and his son, Douglas (“Doug”) Rothrock, were at-will employees.
- Doug claimed he suffered a work-related neck injury while unloading computer equipment in March 1992 and reported it to the employer on May 28, 1992; the employer filed the statutorily required injury report that day.
- Bruce disputed that the injury was work-related and directed Ted to obtain Doug’s signature on a release waiving workers’ compensation benefits.
- Ted testified Bruce threatened that if Doug did not sign, both Doug and Ted would be fired; Ted initially conveyed the threat to Doug but later told him he did not have to sign.
- Doug refused to sign the waiver.
- The dealership terminated Doug in September 1992 and terminated Ted in January 1993.
- Ted and Doug sued for wrongful discharge in violation of public policy; a jury found for both plaintiffs and awarded compensatory and punitive damages, and judgment was entered on the verdict.
- The Superior Court affirmed, including as to Ted on the theory that firing him for refusing to pressure Doug to relinquish workers’ compensation rights violated the same public policy that bars retaliation against claimants.

## Issues

1. Whether an at-will employee discharged for seeking or intending to seek workers’ compensation benefits may maintain a common-law wrongful discharge claim based on Pennsylvania public policy.
2. Whether the workers’ compensation public-policy exception to at-will employment extends to an at-will employee discharged for refusing to coerce another employee into waiving workers’ compensation rights.

## Decision

- The Supreme Court of Pennsylvania affirmed the Superior Court and left intact the judgments for Ted and Doug.
- The Court held Doug’s verdict fit within the established public-policy wrongful discharge rule protecting employees from retaliation for pursuing workers’ compensation benefits.
- The Court held the same public policy also protects an employee fired for refusing to participate in conduct intended to interfere with another employee’s workers’ compensation rights.
- The Court concluded the record supported the jury’s findings that the terminations were motivated by Doug’s workers’ compensation-related injury report and Ted’s refusal to assist in procuring a waiver.

## Legal Principles

- Pennsylvania’s at-will employment rule permits termination for any reason unless the discharge violates a clear mandate of public policy.
- A common-law wrongful discharge action lies where an at-will employee is fired in retaliation for pursuing workers’ compensation benefits.
- The workers’ compensation public policy against coercion and retaliation is violated when an employer discharges an employee for refusing to pressure another employee to surrender workers’ compensation rights.
- Public-policy exceptions remain limited; extension is warranted only where the mandate is clear and the discharge directly implicates that mandate, including efforts to evade protections through intermediaries.

## Conclusion

The court held that the Workers’ Compensation Act’s public policy bars not only retaliation against employees seeking benefits but also retaliation against employees who refuse to help an employer coerce a waiver of another worker’s compensation rights, affirming wrongful discharge verdicts for both the claimant and the refusing supervisor.


Rothrock v. Rothrock Motor Sales, Inc., 584 Pa. 297 (Pa. 2005)