In Sabine Pilot Service, Inc. v. Hauck, 687 S.W.2d 733 (Tex. 1985), the employee was a deck hand for Sabine. He was instructed that one of his duties was to pump the bilges of the boat on which he was working. Id. at 734. After seeing a posted notice stating that pumping bilges into the water was illegal under federal law, and after calling the coast guard to confirm this fact, the employee refused to comply with his employer's order. As a result, he was terminated. Id. In response, the Texas Supreme Court created a "very narrow" exception to the employment-at-will doctrine: an employee cannot be terminated if the sole reason for the termination is the employee's refusal to perform an illegal act that would subject the employee to criminal liability. Id. at 735. The Sabine Pilot exception applies only if the plaintiff was forced to choose between committing a criminal act and being discharged. In the trial of such a case, it is the plaintiff's burden to prove by a preponderance of the evidence that his discharge was for no reason other than his refusal to perform an illegal act. Sabine Pilot, 687 S.W.2d at 735. The Texas Supreme Court set forth a common law exception to the employment at-will doctrine, prohibiting an employer from firing an employee solely because that employee refused to perform an illegal act. 687 S.W.2d at 735. To prevail under the "very narrow" Sabine Pilot exception, the former employee must prove that "his or her discharge was for no reason other than his or her refusal to perform an illegal act." 687 S.W.2d at 735. The Court created an exception to the at-will doctrine for situations in which an employee is fired for refusing "to perform an illegal act." Essentially, the supreme court concluded that the public interest was best served by providing this exception to the general rule. Due to the limited issues that the supreme court was confronted with, the court did not expound upon what type of damages are available under this exception. Although the concurring opinion suggested that punitive damages can be awarded, id. at 736 (Kilgarlin, J., concurring), that suggestion was not and has not been adopted by a majority of the court.