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Swindol v. Aurora Flight Sciences Corp.

Citations: 194 So. 3d 847; 41 I.E.R. Cas. (BNA) 356; 2016 Miss. LEXIS 131; 2016 WL 1165448Docket: No. 2015-FC-01317-SCT

Court: Mississippi Supreme Court; March 24, 2016; Mississippi; State Supreme Court

Narrative Opinion Summary

This case involves a certified question from the Fifth Circuit Court of Appeals concerning the wrongful discharge and defamation claims brought by an employee against his former employer. The employee alleged he was terminated for having a firearm in his locked vehicle on company property, in contravention of Mississippi Code Section 45-9-55. The district court initially dismissed the wrongful discharge claim, citing the absence of a recognized exception to the at-will employment doctrine. However, the Fifth Circuit sought clarity on whether such termination could constitute wrongful discharge under Mississippi law. The court examined whether Section 45-9-55, which prohibits employer policies against storing firearms in locked vehicles, creates a public policy exception to the at-will doctrine. The court concluded that while the statute articulates a public policy against such employer restrictions, it does not provide immunity to employers for wrongful termination claims related to firearm possession in vehicles. The court affirmed that the Mississippi Supreme Court must ultimately decide if Section 45-9-55 constitutes an exception to the at-will doctrine. The court's ruling did not address the dismissed defamation claim, focusing instead on the wrongful termination issue under state law.

Legal Issues Addressed

Employment at Will in Mississippi

Application: The case examines the limitations of the at-will employment doctrine, particularly whether it is subject to exceptions created by legislative action.

Reasoning: Employment at will in Mississippi allows employers to terminate employees for any reason—good, bad, or none—unless the reason is legally impermissible.

Interpretation of Statutory Immunity

Application: The court interprets Section 45-9-55(5) as not providing employers with immunity from liability for wrongful termination related to firearm possession in locked vehicles.

Reasoning: Subsection (5) of the relevant statute is interpreted in a way that does not provide protection to Aurora, as its interpretation would negate the purpose of Subsection (1).

Public Policy Exception to At-Will Employment

Application: The court considers whether Mississippi Code Section 45-9-55 creates a public policy exception to the at-will employment doctrine, potentially preventing employers from terminating employees for storing firearms in locked vehicles.

Reasoning: The main issue is whether this provision creates a new exception to the employment-at-will doctrine.

Statutory Prohibitions on Employer Policies

Application: The court examines how Section 45-9-55 prohibits employers from enforcing policies that prevent employees from storing firearms in locked vehicles on company property.

Reasoning: The relevant Mississippi statute, 45-9-55, prohibits employers from enforcing policies that prevent employees from having firearms in their locked vehicles.