Introduction

The case of Charles J. BROCKMEYER v. DUN BRADSTREET (113 Wis. 2d 561, 1983) marks a significant development in Wisconsin's interpretation of the employment at will doctrine. The Supreme Court of Wisconsin addressed whether any judicial exceptions exist to the employment at will principle, ultimately affirming a narrow public policy exception. This commentary delves into the background of the case, the court's rationale, and the implications of the judgment for future employment law in Wisconsin.

Summary of the Judgment

Charles J. Brockmeyer, employed by Dun Bradstreet since 1969, held a management position until his termination in May 1980. Brockmeyer alleged wrongful discharge, claiming his termination violated public policy, especially after the company settled a sex discrimination claim involving his former secretary. The jury sided with Brockmeyer, awarding significant compensatory and punitive damages. However, upon appeal, the Wisconsin Supreme Court reversed the decision, emphasizing that wrongful discharge under the at will doctrine is only actionable when it contravenes clear and specific public policies established by statute or constitution.

Analysis

Precedents Cited

The court referenced several precedents to frame the employment at will doctrine and its exceptions. Notably:

• Petermann v. Teamsters Local 396 (1959) – Established the public policy exception when an employee is terminated for refusing to engage in illegal activities.
• MONGE v. BEEBE RUBBER CO. (1974) and FORTUNE v. NATIONAL CASH REGISTER CO. (1977) – Explored the implied covenant of good faith and fair dealing in employment contracts.
• Prentiss v. Ledyard (1871) and Yanta v. Montgomery Ward Co. (1974) – Affirmed the longstanding employment at will doctrine in Wisconsin.

The court critically evaluated these precedents, particularly distinguishing between contract and tort theories in wrongful discharge claims.

Legal Reasoning

The Supreme Court of Wisconsin aimed to balance protecting employees from unjust termination with maintaining employers' discretion in workforce management. The court reiterated that the at will doctrine remains robust, allowing termination for any reason not prohibited by law. However, it carved out a limited exception where termination violates a well-defined public policy, such as adherence to statutory mandates or constitutional provisions. The court rejected the broader implied covenant of good faith, deeming it too vague and restrictive.

Impact

This judgment has a profound impact on both employers and employees in Wisconsin. It reinforces the at will doctrine's predominance while providing a narrow pathway for wrongful discharge claims based on explicit public policies. Employers gain clarity on the boundaries of lawful termination, reducing litigation risks related to vague notions of bad faith. Conversely, employees retain a mechanism to challenge dismissals that infringe upon clearly established legal protections, promoting fairness in employment practices.

Complex Concepts Simplified

Employment At Will Doctrine

This legal principle allows either the employer or employee to terminate the employment relationship at any time, for any reason, except for illegal reasons such as discrimination.

Public Policy Exception

An exception to the at will doctrine where termination is deemed wrongful if it contravenes a clear and specific public policy, such as violating a statute or constitutional right.

Implied Covenant of Good Faith

A theoretical requirement that employers act in good faith and deal fairly with employees, although the Wisconsin Supreme Court declined to adopt this as a basis for wrongful discharge claims.

Conclusion

The Supreme Court of Wisconsin, in BROCKMEYER v. DUN BRADSTREET, upheld the employment at will doctrine while recognizing a narrowly defined public policy exception. This decision underscores the necessity for wrongful discharge claims to align with explicit constitutional or statutory mandates. By doing so, the court maintains a balance between employer autonomy and employee protections, ensuring that only terminates breaching fundamental public policies can be contested. This ruling provides clear guidance for future employment disputes in Wisconsin, emphasizing the importance of grounded and specific legal standards in wrongful termination cases.