Haney v. Aramark Uniform Services, Inc., 121 Cal. App. 4th 623 (2004)

Michael Haney, a route sales representative for Aramark and a member of Teamsters Local 431, alleged that his employment was terminated in violation of public policy after he complained to Aramark about its allegedly fraudulent billing practices. Aramark filed a motion for summary adjudication in response to Haney’s wrongful termination claim on the grounds that the claim was preempted by the National Labor Relations Act and Section 301 of the Labor Management Relations Act and that, in any case, Haney had failed to identify a public policy that Aramark had allegedly violated. Although the trial court granted the motion, the Court of Appeal reversed, holding that the claim was not preempted by federal labor law and that "when an employer discharges an employee who refuses to defraud a customer, the employer has violated a fundamental public policy and may be liable in tort for wrongful discharge."