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Pang v. International Document Services
Utah Supreme Court
356 P.3d 1190 (2015)
Facts
Attorney David Pang (plaintiff) worked as in-house counsel for International Document Services (defendant). Pang warned the owners that the company was violating other states’ usury laws by charging interest rates over statutory limits without registering as a lending institution. After six months, Pang took home some loan contracts, created a spreadsheet specifying the number of violations, and shared the spreadsheet with the owners. Two weeks later, the company fired Pang for taking the documents home in violation of the employee handbook. Pang said the company knew of the problems but did not plan to correct them and told him to ignore the noncompliance. Pang sued for wrongful termination, claiming he was fired because the company feared he would expose illegal activities and essentially asked him to violate the Utah ethics rules to keep his job. The district court dismissed Pang’s complaint, reasoning that Pang was an at-will employee whom the company could fire without violating clear and substantial Utah public policy.
Rule of Law
Issue
Holding and Reasoning (Durrant, C.J.)
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