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Abstract

In Dunn v. Enterprise Rent-A-Car Co., the Court of Appeals for the Eastern District of Missouri held that Thomas P. Dunn had presented sufficient evidence to state a cause of action for wrongful discharge for refusing to engage in conduct and for reporting conduct which he reasonably believed violated federal securities laws. Dunn continued Missouri's trend of expanding the availability of wrongful discharge actions to at-will employees terminated in contravention of public policy by merely requiring that the employee "reasonably believe" the instances at issue violate the law. This Note argues that the Eastern District was correct in extending the exception to the employment at-will doctrine under such circumstances because, in general, the protections afforded to employees as a result of the policy outweigh any burdens that may fall on employers.

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