stating that, "[a]lthough there is no precise line of demarcation dividing matters that are the subject of public policies from matters purely personal, *** a matter must strike at the heart of a citizen's social rights, duties, and responsibilities before the tort will be allowed," and noting that public policy is to be "found in the State's constitution and statutes and, when they are silent, in its judicial decisions"
How later courts described this case
- stating that, "[a]lthough there is no precise line of demarcation dividing matters that are the subject of public policies from matters purely personal, *** a matter must strike at the heart of a citizen's social rights, duties, and responsibilities before the tort will be allowed," and noting that public policy is to be "found in the State's constitution and statutes and, when they are silent, in its judicial decisions"
- holding that an "at will” employee who was discharged for reporting his co-workers’ suspected criminal activity to the police stated an actionable claim for common law wrongful discharge because "public policy favors the exposure of crime”
- holding that firing of employee who had reported suspected illegal activity of coworker to police and had agreed to assist in police investigation violated a clear mandate of public policy and gave rise to claim of retaliatory discharge
- finding that at-will employee dismissed for reporting suspected criminal activity by fellow employee to police stated claim for retaliatory discharge because “public policy favors the exposure of crime”
Written by the judges who cited it.
The opinion
MR. JUSTICE UNDERWOOD, dissenting:
For the reasons stated in my dissent in Kelsay v. Motorola, Inc. (1978), 74 Ill. 2d 172, 190 , I believe the court there erred. The thoughts expressed in that dissent regarding judicial self-restraint are equally applicable here. In addition, I share Mr. Justice Ryan’s criticism of the court’s action in this case.