Wandry v. Bull's Eye Credit Union

In Wandry v. Bull's Eye Credit Union, 129 Wis. 2d 37, 384 N.W.2d 325 (1986), an employee of a credit union cashed a payroll check after obtaining her supervisor's approval. See Wandry, 129 Wis. 2d at 39. The check had been stolen, the endorsement forged, and when the issuer of the check stopped payment, the credit union suffered a loss. See id. The employee was discharged when she refused to pay the credit union the total amount of the loss. See Wandry, 129 Wis. 2d at 40. In concluding that the employee's complaint stated a cause of action for wrongful discharge, the supreme court held that: "Sec. 103.455 articulates a fundamental and well-defined public policy proscribing economic coercion by an employer upon an employee to bear the burden of a work-related loss when the employee has no opportunity to show that the loss was not caused by the employee's carelessness, negligence, or wilful misconduct." (Wandry, 129 Wis. 2d at 47.)