view, the public policy considerations raised in Sabine Pilot, i.e., to relieve “at-will” employees from being pressured to eommit criminal acts, would rationally apply to both the employe 12, 230 Ill.Dec. 596, 694 N.E.2d 565, 569-70 (Ill.1998) (no personal liability for retaliatory discharge of subordinate for filing a workers' compensation claim); Rebarchek v. Farmers Coop. Elevator, 272 Kan. 546, 35 P.3d 892, 903-04 (Kan.2001) (same). At the opposite end of the spectrum, Iowa, New Jersey, Pennsylvania, and West Virginia recognize the personal liability of individual non-employers for wrongful termination even when the individual acted within the course and scope of his or her employment in firing another employee. See, e.g., Jasper v. H. Nizam, Inc., 764 N.W.2d 751, 777 (Iowa 2009) (<HOLDING>); Ballinger v. Del. River Port Auth., 172 N.J.
recognizing cause of action for wrongful discharge holding that liability for the tort of wrongful discharge based on refusal to commit an unlawful act can extend to the corporate officers who authorized or directed the discharge recognizing tort of wrongful discharge in violation of public policy recognizing a tort action for wrongful discharge when employee was terminated because he refused to commit a criminal act recognizing tort of wrongful discharge