Utah Supreme Court Upholds Dismissal of In-House Counsel's Wrongful Termination Claim
The Utah Supreme Court issued a decision on August 5, 2015, Pang v. International Document Services , 2015 UT 63, upholding the dismissal of a in-house counsel's complaint alleging that he was terminated for refusing to violate usury laws and the Utah Rules of Professional Conduct. Pang, an at-will employee, asserted that his employer had asked him to violate Rule 1.13(b) of the Utah Rules of Professional Conduct in order to keep his job. The Court held that his firing did not constitute wrongful termination because it did not violate a clear and substantial public policy of the State of Utah, and even if it did, other rules within the Utah Rules of Professional Conduct evince strong policy choices that favor of allowing clients to terminate the attorney-client relationship at any time. The Court began its analysis by noting that in Utah the presumption is that all employees are employed at-will and may be terminated for any reason or no reason, with or wi...