Following Geary v. U.S. Steel (PA Supreme, 1978), the majority of courts applying Geary have required the plaintiff-employee to point to some precise statutory right or duty before ruling the discharge wrongful.

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The Geary case set a precedent where courts often require a clear statutory basis for claims of wrongful discharge, emphasizing the need for a specific legal right or duty to be identified by the plaintiff.

Following Geary V