## Facts

- Emard H. Sheets worked for Teddy’s Frosted Foods, Inc. from about November 1973 to November 1977, serving as quality control director and later operations manager, and received raises and bonuses.
- Sheets found that some products used substandard vegetables and underweight meat components, causing finished goods to conflict with the company’s labeling representations.
- The alleged mislabeling implicated the Connecticut Uniform Food, Drug and Cosmetic Act, which aims to protect public health and prevent consumer deception.
- In May 1977, Sheets wrote to the company about the problems and recommended more selective purchasing and component conformity; his recommendations were ignored.
- On November 3, 1977, Teddy’s terminated Sheets.
- Teddy’s asserted the termination was for unsatisfactory performance; Sheets alleged he was fired for insisting the company comply with statutory labeling and licensing requirements.

## Issues

1. Whether an employer has an unlimited right to discharge an at-will employee hired for an indefinite term.
2. Whether a wrongful discharge claim is stated when an at-will employee alleges termination in retaliation for insisting on compliance with a statute expressing an important public policy.

## Decision

- The Supreme Court of Connecticut reversed the judgment striking the complaint and remanded.
- The court held the at-will termination power is limited by public policy.
- Accepting the pleaded allegations as true, the court held Sheets stated a legally sufficient claim that his discharge violated public policy embodied in the Connecticut Uniform Food, Drug and Cosmetic Act.

## Legal Principles

- Connecticut recognizes a narrow public-policy exception to employment at will when an employee is discharged for conduct tied to a clearly stated public policy.
- Public policy may be derived from statutes that articulate goals protecting the public, including public health and protection against consumer deception.
- An employee should not be forced to choose between continued employment and avoiding participation in, or resisting, conduct that would violate a statutory scheme.
- On a motion to strike, the court assumes the truth of well-pleaded facts and construes them in the pleader’s favor.

## Conclusion

The court permitted an at-will employee to pursue wrongful discharge where he alleged he was fired for pressing his employer to comply with a consumer-protection and public-health statute, holding that statutory public policy can limit an employer’s otherwise broad discretion to terminate.


Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (Conn. 1980)