McManus v. Auchincloss

The public policy underlying ORS 659.550 is "to encourage all employees with a good-faith belief that their employer had committed a crime involving child abuse to report that belief to law enforcement," even if the employee is not required by law to report such information.

McManus brought action against his employer, Auchincloss for wrongful discharge, intentional infliction of emotions distress (IIED), and conversion. McManus claimed he was wrongfully discharged because he reported Auchincloss to the police for possession and display of child pornography. McManus was an at-will employee, but argued he was doing an important public duty by reporting Auchincloss and should be protected. The Court reversed and remanded the trial court's summary judgment for the defendant on the wrongful discharge, IIED, and conversion claims.The Court stated that the public policy expressed by the legislature for ORS 659.550 was "to encourage all employees with a good-faith belief that their employer had committed a crime involving child abuse to report that belief to law enforcement." Reversed and remanded for the wrongful discharge, intentional infliction of emotional distress, and conversion claims; otherwise affirmed.