why her symptoms were not recognized earlier and why treatment had not been timely provided. Plaintiff responded that she had noticed these problems in the past and reported them to her supervisor, Linda Byers, and that it was up to Byers to take some action. She then referred the Calverts to her supervisor.
On June 16, 1986, a staff meeting was held at Hillview Chateau which was attended by plaintiff. At this meeting, plaintiff again raised her concerns about pre-pouring medications and the handling of Mrs. Calvert's case.
On June 18, 1986, plaintiff was presented with an Employee Memorandum containing a list of purported work deficiencies. Defendant informed plaintiff that in order for plaintiff to remain in defendant's employ, she needed to correct these deficiencies immediately.[3]
Plaintiff did not agree withproducts had been inadequately tested and constituted a serious danger to anyone who used it. Following his unsuccessful attempt to get his immediate supervisors to act on this problem, he pressed the matter to the vice-president in charge of the product line. The result of his efforts were twofold; the product was withdrawn from the market and Geary lost his job.
The Geary Court did not conclude that Geary's dismissal was contrary to public policy. In reaching its determination, the Court focused upon two factors; (1) Geary was not responsible for making judgments about product safety, and (2) Geary did not have expertise in that area.
However, the Geary Court did recognize, albeit in dicta, a common law restriction on an employer's power to discharge an at-will employee on public