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Wagenseller v. Scottsdale Memorial Hospital

Arizona Supreme Court
710 P.2d 1025 (1985)



Catherine Wagenseller (plaintiff) was employed as a nurse by Scottsdale Memorial Hospital (hospital) (defendant). Wagenseller’s contract provided that she was an at-will employee. She was directly supervised by Kay Smith (defendant). Wagenseller and Smith worked together amicably for approximately four years. During this time, Wagenseller received favorable performance reviews. In 1979, both Wagenseller and Smith attended an eight-day camping and rafting trip for hospital personnel. During this time, Smith allegedly engaged in heavy drinking and lewd, inappropriate behavior. Wagenseller refused to participate. After the trip, Wagenseller noted that her relationship with Kay deteriorated. She began receiving poor performance reviews, and was eventually terminated from her position. Wagenseller believed her refusal to participate in the camping activities with Smith was the proximate cause of her termination. Wagenseller brought suit against the hospital and Smith for wrongful termination on the ground that she was fired for reasons going against public policy and having nothing to do with her job performance. The trial court ruled in favor of the hospital. The appellate court affirmed, holding only that Wagenseller still had grounds for an action against Smith. Wagenseller appealed.

Rule of Law


Holding and Reasoning (Feldman, J.)

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