Gardner v. Loomis Armored, Inc., 128 Wn.2d 931, 913 P.2d 377 (1996), involved a common law claim for wrongful discharge following the termination of an armored truck driver who left his truck in violation of company policy to rescue a hostage at a bank robbery. Although we found the "situation presented by this case does not fit neatly into . . . the categories of public policy tort cases previously considered by this court," id. at 938, the Court nevertheless found the truck driver had a cause of action for wrongful discharge based on the public policy in favor of protecting human life. Gardner, 128 Wn.2d at 944-46. The Court there identified four necessary elements upon which a common law claim for wrongful discharge in violation of public policy must be heard: (1) The plaintiffs must prove the existence of a clear public policy (the clarity element). (2) The plaintiffs must prove that discouraging the conduct in which they engaged would jeopardize the public policy (the jeopardy element). (3) The plaintiffs must prove that the public-policy-linked conduct caused the dismissal (the causation element). (4) The defendant must not be able to offer an overriding justification for the dismissal (the absence of justification element). (Id. at 941.) The Court extended the tort of wrongful discharge and held the employer, Loomis Armored, violated public policy by discharging an employee for disobeying a company rule in order to save a woman from a life-threatening hostage situation. As Justice Madsen correctly noted in her dissent, the majority there applied the public policy doctrine to a "for cause" employee, refusing to limit the remedy to at-will employment situations: Loomis' employee handbook states that violation of the rule forbidding a driver from leaving an armored vehicle will be grounds for termination. Thus, the majority has applied a formerly narrow exception to the terminable-at-will doctrine to a situation where an employer provided just cause for termination and where the employment-at-will rule is inapplicable. The result of the majority's analysis is that the public policy exception to employment-at-will now applies to a fifth, completely incompatible category; that is, where this court disagrees with an employer's definition of just cause for termination, as set forth in the workplace rules. Gardner, 128 Wn.2d at 952 (Madsen, J., dissenting)