CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Sabine Pilot Service, Inc. v. Hauck

Michael Andrew Hauck, a deckhand, was fired by Sabine Pilot Service, Inc. for refusing to illegally pump bilges into the water, an act he verified as unlawful with the U.S. Coast Guard. Sabine, however, claimed his termination was due to other derelictions of duty. The case, a wrongful discharge suit, saw the trial court's summary judgment in favor of Sabine reversed by the court of appeals. The Texas Supreme Court affirmed the court of appeals' decision, establishing a narrow public policy exception to the employment-at-will doctrine. This exception applies exclusively when an employee is discharged solely for refusing to perform an illegal act that carries criminal penalties, with the burden of proof resting on the plaintiff.

Wrongful DischargeEmployment At WillPublic Policy ExceptionIllegal ActSummary JudgmentEmployer-Employee RelationshipTexas LawCriminal PenaltiesWhistleblower
References
5
Case No. MISSING
Regular Panel Decision

Simmons Airlines v. Lagrotte

Michael Lagrotte, a pilot for Simmons Airlines, Inc., was terminated after refusing to fly a plane in severe icing conditions. Lagrotte sued Simmons for wrongful discharge, claiming he was fired for refusing an illegal act, invoking the Sabine Pilot exception to the employment-at-will doctrine. A jury awarded Lagrotte actual and exemplary damages. Simmons appealed, arguing the Sabine Pilot exception does not apply to 'just cause' employees protected by a collective bargaining agreement, which Lagrotte was. The appellate court agreed with Simmons, holding that the Sabine Pilot exception is narrowly tailored for at-will employees and should not be extended to those with contractual protections like a CBA. Consequently, the court reversed the trial court's judgment and rendered a take-nothing judgment against Lagrotte.

Wrongful DischargeEmployment-at-Will DoctrineSabine Pilot ExceptionJust Cause EmploymentCollective Bargaining AgreementTexas LawAppellate ReviewEmployee RightsEmployer LiabilityAir Safety
References
13
Case No. MISSING
Regular Panel Decision

Nguyen v. Technical and Scientific Application, Inc.

Nguyen, a network engineer for TSA, refused to load software he believed violated federal criminal copyright laws. He was subsequently demoted and experienced intolerable working conditions, leading to his resignation in February 1997, which he considered a constructive discharge. Appellants (Nguyen) sued for wrongful termination under the Sabine Pilot exception, traditionally applied to employees fired for refusing an illegal act. The trial judge initially struck the claim and later granted summary judgment, asserting the Sabine Pilot exception did not apply to constructive discharges. However, the appellate court reversed this decision, holding that the Sabine Pilot exception extends to employees constructively discharged for refusing to commit a crime, thereby preventing employers from evading liability by coercing resignations.

Constructive DischargeWrongful TerminationSabine Pilot ExceptionEmployment-at-WillIllegal ActRefusal to Commit CrimeTexas LawAppellate ReviewSummary JudgmentCopyright Infringement
References
15
Case No. No. 10-96-049-CV
Regular Panel Decision
Dec 18, 1996

Matthew Carroll v. Kermit Black

Matthew Carroll sued several Texas A&M University officials claiming wrongful discharge. The defendants filed a plea to the jurisdiction asserting the defense of sovereign immunity, which the trial court granted. Carroll appealed, questioning if the Sabine Pilot exception to the employment-at-will doctrine applies to public employees asserting sovereign immunity. The court affirmed the trial court's judgment, stating that without legislative consent or a statutory exception, sovereign immunity applies and is not overcome by the Sabine Pilot exception in this context.

wrongful dischargesovereign immunityemployment-at-will doctrineSabine Pilot exceptionpublic employeesplea to jurisdictionTexas A&M Universityappellate reviewgovernmental immunity
References
5
Case No. MISSING
Regular Panel Decision

PHYSIO GP, INC. v. Naifeh

Senior Justice J. Harvey Hudson dissents from the majority opinion, which held that the Sabine Pilot exception to the employment-at-will doctrine does not extend to individual defendants who are not the direct employer. The dissent argues that a corporate employee, like Tanja Saadat in this case, should be held personally liable for wrongful termination if their actions constitute an intentional tort based on malice. The dissent highlights that Naifeh was allegedly fired by Tanja Saadat for refusing to participate in an insurance fraud scheme, followed by a campaign to destroy Naifeh's professional reputation. Hudson asserts that the tort of wrongful termination is intensely personal, not contractually derived, and that the public policy underlying Sabine Pilot should extend to agents of the employer to deter criminal acts.

Wrongful DischargeEmployment-at-WillSabine Pilot ExceptionIndividual LiabilityCorporate Officer LiabilityRetaliatory DischargeIntentional TortPublic PolicyTexas LawInsurance Fraud
References
20
Case No. 14-12-00991-CV
Regular Panel Decision

Joseph Peine v. HIT Services L.P., Wood Group USA, Inc., John Wood Group PLC, Wood Group Power GP, LLC and Wood Group Management Services, Inc.

Joseph Peiner, a former CFO, sued his employer and related entities for wrongful termination, alleging he was fired for refusing to commit a crime (inflating profits). The trial court granted summary judgment in favor of the appellees. On appeal, Peiner argued there was a genuine issue of material fact regarding whether his refusal was the sole cause of his termination, as required by the Sabine Pilot exception to the employment-at-will doctrine. The appellate court affirmed the summary judgment, finding that the evidence conclusively proved Peiner was terminated, at least in part, for breaching his confidentiality duties by sending company documents to a reporter. The court rejected Peiner's arguments, emphasizing that Sabine Pilot requires the illegal act refusal to be the sole cause of termination and does not protect employees for reporting illegal activities.

Wrongful TerminationEmployment LawSabine Pilot ExceptionSummary JudgmentConfidentiality BreachWhistleblower ProtectionRetaliatory DischargeTexas Appellate CourtCorporate GovernanceFinancial Misconduct
References
28
Case No. 03-08-00626-CV
Regular Panel Decision
Apr 23, 2010

Safeshred, Inc. v. Louis Martinez, III

Louis Martinez, III, an employee of Safeshred, Inc., was terminated after refusing to drive a commercial vehicle he deemed unsafe and noncompliant with federal and state regulations. Martinez sued Safeshred, alleging wrongful termination under the Sabine Pilot exception to the at-will employment doctrine. A jury awarded Martinez economic damages, compensatory damages for non-economic losses including mental anguish, and exemplary damages. Safeshred appealed, challenging the availability and sufficiency of exemplary and compensatory damages. The Court of Appeals affirmed the awards for economic and exemplary damages, finding punitive damages are proper in Sabine Pilot actions and supported by evidence of malice. However, the court reversed the award for compensatory damages for mental anguish, ruling that the evidence presented did not meet the legal sufficiency standard for such damages in Texas law.

Retaliatory DischargeAt-Will EmploymentSabine Pilot DoctrinePunitive DamagesCompensatory DamagesMental AnguishLegal SufficiencyFactual SufficiencyCommercial Vehicle SafetyFederal Motor Carrier Regulations
References
47
Case No. MISSING
Regular Panel Decision

Lovelace v. Sabine Consolidated, Inc.

Sabine Consolidated, Inc. sued Jesse R. Lovelace for breach of contract, breach of fiduciary duty, and fraud related to joint venture agreements for sewer construction projects in Houston. Lovelace appealed a jury verdict that awarded Sabine actual damages, punitive damages, and attorneys' fees. The appellate court affirmed the judgment but modified it by reversing the award of punitive damages due to the lack of independent findings of damages in tort, and by overturning the award for lost profits on a separate New Caney project due to insufficient evidence. The court also upheld the trial court's decisions regarding discovery and cross-examination related to an Austin project and affirmed the constitutionality of the supersedeas bond rule.

Breach of ContractBreach of Fiduciary DutyFraudJoint Venture AgreementPunitive DamagesActual DamagesLost ProfitsContract EnforceabilityAppellate ReviewDiscovery Abuse
References
20
Case No. MISSING
Regular Panel Decision

Safeshred, Inc. v. Martinez

This case clarifies the nature and scope of the wrongful termination cause of action recognized in Sabine Pilot Service, Inc. v. Hauck. Martinez, a truck driver for Safeshred, was fired for refusing to drive unsafe and illegal loads despite repeated orders. The core issue was whether a Sabine Pilot action allows punitive damages and, if so, under what conditions, particularly regarding the definition of malice. The Court held that a Sabine Pilot claim sounds in tort and allows punitive damages upon proper proof of malice related to the firing itself, not the illegal act requested. However, the Court found Martinez failed to present legally sufficient evidence of malice in his firing, thus reversing the award of exemplary damages while affirming other aspects of the court of appeals' judgment.

Wrongful terminationSabine Pilot claimPunitive damagesExemplary damagesMaliceAt-will employment doctrineTort lawContract lawEmployee rightsWorkplace safety
References
36
Case No. MISSING
Regular Panel Decision

Carroll v. Black

Matthew Carroll sued officials from Texas A & M University, alleging wrongful discharge. The defendants successfully filed a plea to the jurisdiction based on sovereign immunity, which the trial court granted. Carroll appealed, raising the question of whether the Sabine Pilot exception, which protects employees discharged for refusing to perform illegal acts, applies to public employees where sovereign immunity is asserted. The appellate court concluded that neither legislative consent nor a statutory exception to sovereign immunity existed in this case. Consequently, the court affirmed the trial court's judgment, upholding the dismissal of Carroll's suit against the state officials.

wrongful dischargesovereign immunityemployment-at-willSabine Pilot exceptionpublic employeesgovernmental immunityappellate reviewemployment lawTexas lawstatutory interpretation
References
5
Showing 1-10 of 1,208 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational