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Byers v. Creative Corner, Inc.
Citations: 57 P.3d 1064; 2002 UT 96; 456 Utah Adv. Rep. 13; 2002 Utah LEXIS 139; 2002 WL 31055932Docket: No. 20000782
Court: Utah Supreme Court; September 17, 2002; Utah; State Supreme Court
Angela Byers, an at-will employee, claimed wrongful termination by her employer, Creative Corner, Inc., alleging it violated public policy against sex discrimination by terminating her due to her pregnancy. Creative Corner, which employs fewer than fifteen individuals, filed a motion to dismiss under rule 12(b)(6) for failure to state a claim, which the trial court granted. Byers subsequently sought a new trial under rule 59, but her motion was denied, prompting her appeal. Byers contended that the trial court erred in determining that no cause of action for wrongful termination based on alleged public policy against sex discrimination exists in Utah. She requested the appellate court to reverse the trial court's decision and remand for a trial on the merits. In contrast, Creative Corner argued that any common law cause of action for employment discrimination is superseded by the Utah Anti-Discrimination Act, asserting that Utah lacks a clear public policy against gender discrimination. The court referenced its previous ruling in Gottling v. P.R. Inc., where it established that the Utah Anti-Discrimination Act preempts all state common law remedies for discrimination, including those based on sex, race, color, pregnancy, age, religion, national origin, or disability. Consequently, the court affirmed that Byers could not pursue her wrongful termination claim against Creative Corner, validating the trial court's dismissal of her complaint and denial of her new trial motion. The opinion was concurred by Associate Chief Justice Durrant, Justice Russon, and Justice Wilkins.