unlawful harm under that public policy may include actions that violate recognized and accepted standards of conduct, such as applicable codes of ethics. The critical question in this case is whether under all of the surrounding circumstances MacDougall’s termination by Weiehert violated that clear mandate of public policy and was in retaliation for either his vote on the municipal parking ban ordinance or his refusal to change the ordinance. At the outset, we recognize that conduct that is directed against constitutionally-protected activity may violate a clear mandate of public policy, even though it may not offend any other statutory or legal standard. Supra at 390, 393, 677 A.2d at 167, 168. Compare Shovelin v. Central New Mexico Elec. Coop., Inc., 115 N.M. 293, 850 P.2d 996 (1993) (<HOLDING>) with Novosel v. Nationwide Ins. Co., 721 F.2d
holding that employees retaliatory discharge based on employees election to public office did not violate public policy recognizing public policy limits on employer discretion in discharging employees holding public employees conduct and expression in internal investigation of employees at county prosecutors office to expose potential wrongdoing constituted matter of public concern recognizing retaliatory discharge claim where employer prevented employees exercise of workers compensation rights because of employees intention to file claim holding that the discharge of an employee hospitalized for illness did not violate public policy