## Facts

- Anita Wright, a registered nurse, worked for Shriners Hospital for Crippled Children in Boston from 1976 until late February 1987 and was an at-will employee.
- Wright became assistant director of nursing and received consistently excellent evaluations, including in December 1986.
- In June 1986, a former nurse wrote to the organization’s national headquarters raising concerns about the hospital’s medical staff and administration.
- National headquarters informed hospital administrator Salvatore Russo that a survey team would visit in November 1986; Russo reacted angrily and suggested Wright may have been involved.
- During the survey, Wright spoke with the team about hospital operations and morale, including problems in nursing–medical staff relations.
- After the survey and subsequent workplace friction, Russo terminated Wright’s employment.
- Wright sued Shriners for wrongful discharge in violation of public policy and sued Russo for intentional interference with her at-will employment relationship.
- A jury awarded Wright $100,000 against Shriners and $50,000 against Russo; the trial court denied defendants’ motions for judgment notwithstanding the verdict (JNOV).

## Issues

1. Whether firing an at-will nurse in alleged reprisal for criticism given to a survey team from the employer’s national organization states a wrongful-discharge claim under Massachusetts’ public-policy exception.
2. Whether a hospital administrator can be liable for intentional interference with an at-will employment relationship where the employer could lawfully discharge the employee and there was no evidence the administrator acted from a purpose unrelated to a legitimate corporate interest.

## Decision

- The Supreme Judicial Court reversed the judgments for Wright and remanded for entry of judgment for the defendants.
- The court held that, even if Wright was fired in reprisal for her criticisms to the affiliated survey team, the discharge did not violate a well-defined public policy recognized by Massachusetts law.
- The court held Russo was entitled to JNOV on the interference claim because the hospital was legally entitled to discharge Wright and there was no evidence Russo acted with a purpose unrelated to a legitimate corporate interest.
- Chief Justice Liacos dissented.

## Legal Principles

- Massachusetts recognizes a narrow public-policy exception to at-will employment, generally limited to terminations for asserting a legally guaranteed right, performing a legal duty, or refusing to commit an unlawful act.
- Internal, voluntary criticism about workplace management conveyed to an employer-affiliated review body, without linkage to a statutory right or legal obligation, does not satisfy the public-policy exception.
- A corporate officer or supervisor is not liable for intentional interference with an employee’s relationship with the corporation when the corporation has the legal right to terminate and the officer’s actions further a legitimate corporate interest.
- For interference liability against a corporate official in the employment setting, the plaintiff must show improper motive (such as “actual malice”) or a purpose disconnected from the employer’s legitimate interests.

## Conclusion

The court held that retaliation against an at-will nurse for criticizing hospital operations to an affiliated survey team is not actionable under the public-policy exception, and that a hospital administrator is not liable for intentional interference absent evidence of an improper purpose unrelated to the employer’s legitimate interests.


Wright v. Shriners Hosp. for Crippled Children, 412 Mass. 469, 589 N.E.2d 1241 (Mass. 1992)