Marcy v. Delta Airlines
United States Court of Appeals for the Ninth Circuit
166 F.3d 1279 (9th Cir. 1999)
Marcy (plaintiff), a longtime Delta (defendant) employee generally considered outstanding, submitted a payroll document with three unintentional errors; despite Delta's own practice of consulting employees about common payroll discrepancies, Delta terminated her, citing the errors alongside a prior incident where she'd falsified phone logs for personal calls. A jury found Marcy's payroll errors unintentional and that Delta had wrongfully discharged her under Montana's Wrongful Discharge from Employment Act (WDEA); the district court denied Delta's post-trial motions, and Delta appealed.
Whether, under Montana's Wrongful Discharge from Employment Act, an employer who fires an employee based on mistaken facts may be liable for wrongful discharge, regardless of good faith.