English v. General Electric Co.
United States Supreme Court
496 U.S. 72 (1990)
Vera English (plaintiff) worked as a lab technician for General Electric Company (GE) (defendant) at its nuclear-fuels production facility in Wilmington, North Carolina. In February 1984, English complained to company management and to the Nuclear Regulatory Commission about safety violations including her coworkers’ failure to clean up spills of radioactive material. Upon receiving what she perceived as inadequate attention to the matter, English purposely left a table contaminated, pointing it out to a supervisor after the table went uncleaned for days. English was fired a few months later. In August, she filed an administrative complaint with the Secretary of Labor, alleging that GE had violated § 210(a) of the Energy Reorganization Act of 1974 (ERA), which prohibited retaliation against whistleblowers in the nuclear industry. The Secretary dismissed the complaint because English had failed to file it within the required 30-day time period following her termination. In 1987, English filed a diversity action against GE, asserting claims of wrongful termination and intentional infliction of emotional distress (IIED), in a federal district court in North Carolina. She sought compensatory and punitive damages. The court ruled that English had stated a valid IIED claim under North Carolina law but that the claim was preempted by conflict with § 210 of the ERA. The court based its conclusion on three aspects of the ERA: (1) its nonapplication to whistleblowers who deliberately cause a violation of the ERA, (2) its lack of a provision authorizing punitive damages, and (3) its strict 30-day time period for filing a complaint thereunder. The Court of Appeals for the Fourth Circuit affirmed. English petitioned the United States Supreme Court for certiorari. GE argued that both field and conflict preemption applied.
Rule of Law
Holding and Reasoning (Blackmun, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 725,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 725,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.