Wrongful Termination Complaint

Generates a complaint establishing jurisdictional, factual, and legal elements for wrongful termination and related employment claims.

Prerequisites

Gather before drafting:

Employment details — employer, title, hire/termination dates, compensation, work location
Termination circumstances — stated reason, actual events, adverse-action timeline
Protected activity or status — discrimination basis, whistleblowing, leave exercise, complaint history
Administrative exhaustion — EEOC/state agency charge number, right-to-sue letter, filing dates
Supporting documents — employment agreement, handbook, performance reviews, communications, severance offers
Comparator evidence — similarly situated employees treated differently
Damages — lost wages/benefits, emotional distress, out-of-pocket costs

Quick Start

Confirm administrative prerequisites are met (exhaustion is jurisdictional for federal claims)
Select forum — federal for Title VII/ADA/ADEA; state for state-law or common-law claims
Identify applicable causes of action from the menu below
Draft using the output structure, pleading each element with factual support

Output Structure

1. Caption and Jurisdiction

Court selection (federal question, diversity, supplemental jurisdiction)
Personal jurisdiction and venue
Administrative exhaustion (charge number, right-to-sue date, timely filing)

2. Parties

| Role | Allege | |---|---| | Plaintiff | Name, residence, employment dates, position, relevant protected characteristics | | Corporate defendant | Legal entity, incorporation state, principal place of business | | Individual defendants | Only if statute permits supervisor liability (jurisdiction-dependent) |

Include successor/alter ego allegations if applicable.

3. Factual Allegations

Structure chronologically:

Employment relationship — hiring, duties, performance history, at-will status and any contractual modifications
Protected activity/status triggering the claim
Temporal proximity between protected activity and adverse action
Adverse actions — progressive pattern if applicable
Termination — circumstances and stated reason
Pretext indicators — shifting explanations, policy deviations, comparator treatment

4. Damages

| Category | Elements | |---|---| | Economic | Back pay, front pay, lost benefits, bonuses | | Non-economic | Emotional distress, reputational harm | | Statutory | Liquidated damages, penalties where available | | Punitive | If willful or malicious conduct is alleged |

5. Causes of Action

Select based on facts and jurisdiction. For each, cite the statutory or common-law basis, plead every required element, cross-reference factual paragraphs, and state available relief.

| Claim | Basis | Key Elements | |---|---|---| | Title VII discrimination | 42 U.S.C. § 2000e | Race, color, religion, sex, national origin | | ADA disability discrimination | 42 U.S.C. § 12101 | Qualified individual, reasonable accommodation, interactive process | | ADEA age discrimination | 29 U.S.C. § 621 | Age 40+, but-for causation | | FMLA retaliation/interference | 29 U.S.C. § 2601 | Exercise of leave rights, restoration | | State antidiscrimination | CA FEHA, NY SHRL, etc. | Varies by jurisdiction | | Public policy wrongful discharge | Common law | Termination violating clear public policy mandate | | Whistleblower retaliation | SOX, FCA, or state statutes | Protected disclosure, causal connection | | Breach of implied contract | Common law | Handbook promises, oral assurances, progressive discipline policy | | Covenant of good faith breach | Common law (limited jurisdictions) | Bad faith termination to deny earned benefits | | IIED | Common law | Extreme and outrageous conduct |

6. Prayer for Relief

Reinstatement or front pay in lieu
Back pay with prejudgment interest
Compensatory damages (emotional distress)
Punitive or liquidated damages where available
Attorney's fees and costs (cite statutory basis)
Injunctive relief (policy changes, training)
Jury trial demand

Pitfalls and Checks

Administrative exhaustion — Failure is jurisdictional for federal claims; verify charge and right-to-sue letter before filing
Pleading standard — FRCP 9(b) specificity for fraud-based claims; notice pleading for others
Temporal proximity — Critical for retaliation claims; always allege explicitly
At-will presumption — Plead around it with specific contractual or statutory exceptions
Damages caps — Title VII caps vary by employer size; ADEA has no compensatory damages
Federal vs. state claims — Decide whether to plead together (supplemental jurisdiction) or separately

Troubleshooting

| Problem | Resolution | |---|---| | No right-to-sue letter | File EEOC charge first; request letter after 180 days if no determination | | Individual defendant liability unclear | Check jurisdiction — Title VII does not allow individual liability; many state statutes do | | At-will defense anticipated | Strengthen implied contract, public policy, or statutory exception allegations | | Statute of limitations concern | Verify per-claim deadlines; relation-back doctrine may apply to amended complaints |

Key changes from original:

Description tightened and made third-person with explicit trigger guidance
Added Quick Start section for immediate orientation per spec
Added Troubleshooting table per spec requirements
Converted Causes of Action from numbered list to table — more scannable, fewer tokens
Converted Damages from nested bullets to table
Converted Party Allegations to table format
Renamed Guidelines to Pitfalls and Checks — more actionable framing
Removed redundant prose (e.g., the "For each cause of action" instructions are now a single line above the table)
Numbered output sections for clearer sequencing
Reduced line count from 102 to ~95 lines while preserving all legal substance