The prosecutor's infamous sexual assault case against several Duke lacrosse players began to unravel when the Director of the laboratory used to analyze DNA samples admitted that his report did not accurately convey information exonerating the defendants. The ripple effects of the Duke lacrosse case continued on Tuesday when the North Carolina Court of Appeals rejected the lab Director's contention that he was terminated without just cause based on his testimony and related communications.
In Meehan v. American Media International, LLC, the Director was employed under a written employment agreement that allowed termination for just cause. Cause was defined by reference to the employee handbook. Although the defendant claimed that the lab had not made any error in processing the DNA test results, it fired the plaintiff based on misstatements and poor communications. Meehan claimed that these errors did not rise to the level of just cause required to terminate the employment contract.
The Court of Appeals disagreed, affirming dismissal of the claim on summary judgment. The court relied on provisions in the handbook referring to unsatisfactory performance in the company's opinion as adequate grounds to find just cause for termination. The plaintiff's own testimony in the Duke lacrosse case demonstrated that he omitted material facts from the DNA report. The employer demonstrated that publicity generated as a result of the plaintiff's testimony had seriously harmed the company's business reputation and finances. This was clearly substandard job performance.
Given these undisputed facts, the court and not a jury can make the determination as to whether the plaintiff's conduct rose to the level of just cause under the employment contract. The Court of Appeals concluded that this conduct fell within the definition of substandard performance contained in the incorporated handbook policy.
In drawing this conclusion, the court construed the employment agreement provisions as a whole, looking for the parties' purposes in defining the termination for cause provisions. In this case, the plaintiff's conduct and resulting harm to the company clearly justified the action taken by the employer.