62 Va. L. Rev. 481 (1976)
Individual Protection against Unjust Dismissal: Time for a Statute

handle is hein.journals/valr62 and id is 491 raw text is: INDIVIDUAL PROTECTION AGAINST UNJUST
DISMISSAL: TIME FOR A STATUTE *
Clyde W. Summers **
G EORGE Geary, who had been employed by United States
E     Steel Corporation for fourteen years, was a salesman of tubu-
lar products used in the oil and gas industry. When the company
began to market a new casing designed to be used under high pres-
sure, he told his superiors that he believed it had not been ad-
equately tested and constituted a serious danger to anyone who
used it. He was ordered to follow directions and agreed to do so,
but he expressed his misgivings to a vice-president in charge of
sales of the product whom he knew personally. As a result of his
efforts, the tube was reevaluated and withdrawn from the market.
Because of this his superiors summarily discharged him. He
brought suit claiming that his discharge was without cause, was
contrary to public policy, and constituted a prima facie tort.
The Supreme Court of Pennsylvania dismissed the complaint.'
Geary's suit, said the court, beckon[s] us into uncharted terri-
tory, 2 for his employment was at will. In such employment the
law has taken for granted the power of either party to terminate
an  employment relationship       for any or no      reason. 3 justice
Roberts, in dissent, pointed out that Geary had not violated any
duty toward his employer, but had acted in the best interests of his
employer and of society in preventing the sale of unsafe products.4
Unafraid of uncharted territory, the dissent declared: Unlike
* This article is based on a paper presented at the American Arbitration Association's
conference on The Future of Labor Arbitration, convened in celebration of the Associa-
tion's 50th anniversary. It is dedicated here to Bernard Dunau because of his lifelong
interest in the rights of individual employees. See Dunau, Employee Participation In The
Grievance Aspect of Collective Bargaining, 50 COLUMi. L. REv. 731 (1950); Dunau, Com-
ment on Summers, The Individual Employee's Rights Under The Collective Agreement:
What Constitutes Fair Representation, in NATIONAL ACADEMY OF ARBiTRATORS, APBrrA-
TioN-1974 38 (Proceedings of the Twenty-Seventh Annual Meeting, 1975).
* * Fordham Professor of Law, University of Pennsylvania Law School.
1 Geary v. United States Steel Corp., 456 Pa. 171, 319 A.2d 174 (1974).
2 Id. at 174, 319 A.2d at 175.
3 Id. at 175, 319 A.2d at 176.
4 Id. at 186-92, 319 A.2d at 181-84.

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