Pang v. Int’l Document Servs., 2015 UT 63 (August 5, 2015)

Plaintiff, who was in-house counsel, sued his employer alleging he was terminated for refusing to ignore the company’s violation of several states’ usury laws. The trial court dismissed his complaint without hearing on the basis that plaintiff was an at-will employee, and had failed to demonstrate a substantial public policy exception to at-will employment. The Supreme Court affirmed, holding Rule of Professional Conduct 1.13(b) “does not constitute a clear and substantial public policy that prevents the termination of an at-will employee.” It further reasoned, “other rules of professional conduct evince strong policy choices that favor allowing clients to terminate the attorney-client relationship at any time, including firing an in-house lawyer with whom an organizational client disagrees.”