In a wrongful discharge action based on the public policy exception to the employment-at-will doctrine courts created a sleeper claim favoring terminated at will employees.' Generally, Missouri courts categorically constrain the public policy exception in a narrow and clear cut fashion. However, some Missouri courts pushed and rubbed at the bright lines of those categories and created a hazy area of unpredictability in the exception. In addition, federal courts interpreting the Missouri public policy exception introduced a significant pre-emption dispute which Missouri state courts have yet to address.

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