Schweiss v. Chrysler Motors Corp.

Ann Schweiss (plaintiff) worked at Chrysler Motors Corp. (Chrysler) (defendant) for five years. Chrysler fired Schweiss shortly after she reported alleged violations of the Occupational Safety and Health Act (OSHA) to the Occupational Health and Safety Administration. Chrysler claimed to have fired Schweiss for frequent absences. However, Schweiss claimed to have been fired for whistleblowing, and she filed a wrongful-discharge claim in a Missouri state court against Chrysler and Perry Sigwerth (defendant), her former supervisor, both of whom removed the complaint to a federal district court. Sigwerth moved for dismissal, which the district court granted on the ground that OSHA preempted Schweiss’s claim for wrongful termination under Missouri law. Although Missouri was an at-will employment state, an employee could sue an employer for wrongful discharge if the employee’s termination was because the employee had declined to break the law or had reported that the employer had violated the law. The district court ruled that Missouri law was preempted because allowing employees to sue for retaliatory discharge pursuant to state law would frustrate the remedy provided under federal law. The district court held that a suit under Missouri law would frustrate Congress’s goal of having occupational complaints screened by the Occupational Health and Safety Administration prior to reaching a federal court and would prevent the secretary of labor from being the plaintiff bringing the suit, as was required under OSHA. Schweiss appealed. The appellate court considered the issue of preemption.