Exercising statutory right doesn't invoke narrow public policy exception

n addition to the antidiscrimination laws, Massachusetts recognizes a public policy exception to at-will employment. In a recent case, an at-will employee who was terminated after submitting a lengthy rebuttal to his performance improvement plan (PIP) argued he was wrongfully discharged in violation of public policy for exercising his legal right to submit the rebuttal under the state's personnel file statute. In rejecting the argument, the appeals court highlighted the narrowness of the public policy exception to the at-will employment doctrine.

Facts

Terrence Meehan was an at-will employee of Medical Information Technology, Inc. (d/b/a Medictech). According to his complaint, he began working as a sales representative for Meditech in November 2010. In April 2017, he was one of three sales representatives essentially demoted to the position of sales specialist, while nine others remained in their sales representative roles.

In July 2018, Meehan and the other two sales specialists were placed on a PIP. Approximately two weeks later, he wrote a lengthy rebuttal to the PIP and e-mailed it to his supervisor. After receiving the rebuttal, members of Meditech's management met to discuss it, and they decided he should be terminated the same day.

Personnel file statute