Sue Ann Dolan worked for Continental Airlines as a ticketing agent. Because of the Persian Gulf War, airport security was tightened countrywide. Airport employees were given information and profiles on persons that may give cause for concern from drug and terrorist activities. Employees were asked to report anyone that may fit such profiles to airport security. Dolan did so and an arrest was made by the Federal Drug Enforcement Agency (DEA). Dolan reported a second incident and was promised a reward by the DEA.

Continental then released a written notice stating that any such reports must be made to a manager of Continental prior to any contact with an outside agency. After the notice was posted, Dolan had contact with the DEA. When confronted by Continental, she denied contact but after supporting evidence of contact was made in writing by fellow employees alleging that Dolan had turned two passenger names into the DEA, Dolan admitted contact but stated it was just for the purposes of determining the status of her reward. Dolan's employment was terminated. She filed and refiled suit against Continental finally consolidating reasons for wrongful discharge in violation of public policy and breach of contract as well as under the Whistleblower's Protection Act (WPA).

The trial court dismissed the complaint with prejudice, the Court of Appeals affirmed. The decision of the Michigan Supreme Court determined that there was no action for wrongful discharge in violation of public policy nor for breach of contract but there was protection under the WPA.

Dolan v. Continental Airlines/Continental Express, No. 97-102413, Sue Ann Dolan, Plaintiff-Appellant vs. Continental Airlines/Continental Express, a Delaware corporation, Defendant-Appellee. Michigan Supreme Court, Lansing, Michigan. May 20, 1997.