Pickering v. Teladoc Health, Inc.

CourtDistrict Court, D. Delaware
DecidedOctober 1, 2025
Docket1:24-cv-00445
StatusUnknown

This text of Pickering v. Teladoc Health, Inc. (Pickering v. Teladoc Health, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pickering v. Teladoc Health, Inc., (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JOSEPH T. PICKERING, ) Plaintiff, v. ) ) C.A. No. 24-445-RGA-SRF TELADOC HEALTH INC.,, ) Defendant. )

REPORT AND RECOMMENDATION Presently before the court in this employment suit for wrongful termination is Defendant Teladoc Health, Inc.’s (“Defendant”) motion to dismiss Plaintiff Joseph Pickering’s (“Plaintiff”) First Amended Complaint (“FAC”) for failure to state a claim, pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. (D.I. 28)' For the reasons that follow, I recommend the court GRANT-IN-PART and DENY-IN-PART Defendants’ motion to dismiss Counts I, I and III of the FAC, I. BACKGROUND This matter arises from Defendant’s termination of Plaintiff's employment on March 23, 2023. (D.I. 27 at | 28-29) Plaintiff began his employment with the Defendant as a consultant in September of 2020. Ud. at 7) He assumed a full-time position in September of 2021, as a Director and “Release Train Engineer” (“RTE”) of the Company’s product known as “Primary 360.” Ud. at § 8) He began a new position as Senior Director of Operations Risk Management and Corporate Insurance in May of 2022, (/d, at § 10) Although Defendant worked remotely

| The briefing associated with this motion can be found at D.I. 29, D.I. 30, and D.I. 31.

from his Delaware residence, he was required to travel to Teledoc’s New York office on several occasions over the course of his employment . Ud. at § 13) As a Senior Director, Plaintiff was responsible for preparing and executing Operations Risk Assessments (“ORA”) for Teledoc’s business units which included BetterHelp, a Teledoc subsidiary. Ud. at |] 10) BetterHelp is a mental health platform that provides online mental health services to consumers, (/d. at 915) The FAC alleges that BetterHelp was the subject of an investigation by the Federal Trade Commission (“FTC”) for alleged unfair and deceptive trade practices related to improper disclosure of highly sensitive health information about its users and visitors. (d.) Plaintiff was tasked with assessing five objectives of BetterHelp in the ORA. Plaintiff understood that the ORA was a risk assessment that was required by the FTC. Plaintiff identified in his assessment the following inherent risks: (1) lack of execution to attract and retain a top-quality workforce that could impede core business processes; (2) lack of awareness or understanding of regulatory and compliance environments of global markets; (3) lack of ability to ensure system availability; prevent fraudulent activity, and to secure confidential corporate and consumer data; (4) lack of proper credentialing and credential management of therapists; and (5) lack of strategic leveraging of integration opportunities into Teladoc as a shared service. 27 at § 20) On October 27, 2022, Plaintiff presented his ORA findings at an internal meeting of employees and executives within BetterHelp. (/d. at § 25) The FAC alleges that the President of BetterHelp, Matos, directed Plaintiff and others to rewrite the ORA with a more positive assessment of the findings. Z¢@. Matos was also a member of Teledoc’s executive team. (Ud. at 23) The following day, Plaintiff filed an internal complaint on Teledoc’s Ethics Hotline alleging that BetterHelp’s President directed him and other employees to alter and/or falsify the

BetterHelp ORA during the October 27, 2022, meeting. (/d. at 927) Teledoc maintains a Code of Business Conduct and Ethics policy which prohibits retaliation against an employee for engaging in whistlebiowing conduct. (/d. at {| 14) Teladoc engaged independent counsel to investigate the reported ethical violation. (id. at ] 28) The investigation failed to substantiate Plaintiffs allegations about the conduct of BetterHelp’s President or that the BetterHelp ORA was intended to provide any false, misleading or inaccurate information to the FTC. Ud.) Plaintiff was informed of the foregoing results of the investigation in March of 2023, through emailed correspondence. Vd.) Plaintiff contends that within minutes of his receipt of the results of the investigation, he was required to remotely attend a meeting with Defendant’s human resources representatives who informed him that he was laid off immediately due to the elimination of his position, Ud. at ] 29) Plaintiff filed the instant suit on April 9, 2024. (D.I. 1) The FAC was filed on October 22, 2024 alleging three causes of action: violation of the Delaware Whistleblower Protection Act (“DWPA”) (Count I); breach of the Implied Covenant of Good Faith and Fair Dealing (Count and violation of the New York Whistleblower Protection Law (Count IT), Defendant moves to dismiss all three counts for failure to state a claim pursuant to Rule 12(b)(6) and lack of subject matter jurisdiction as to Count Ii, pursuant to Rule 12(b)(1). (D.I. 27) The motion was fully briefed and referred to the undersigned judicial officer on April 15, 2025. (D.I. 32) Il. LEGAL STANDARDS A. Rule 12(b)(6) — Failure to State a Claim Rule 12(b)(6) permits a party to seek dismissal of a complaint for failure to state a claim upon which relief may be granted. Fed. R. Civ. P. 12(b)(6). To state a claim pursuant to Rule 12(b)(6), a complaint must contain a “short and plain statement of the claim showing that the

pleader is entitled to relief.” Fed, R, Civ. P. 8(a)(2). Although detailed factual allegations are not required, the complaint must set forth sufficient factual matter, to “state a claim to relief that is plausible on its face.” Bell Atl. Corp, vy. Twombly, 550 U.S, 544, 570 (2007); see also Ashcroft v. igbal, 556 U.S. 662, 663 (2009). In assessing the plausibility of a claim, the court must “accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Fowler vy. UPMC Shadyside, 578 F.3d 203, 210 Gd Cir, 2009) (quoting Phillips v. Cuty. of Allegheny, 515 F.3d 224, 233 Gd Cir. 2008)). A claim is facially plausible when the factual allegations allow the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Igbal, 556 U.S. at 663; Twombly, 550 U.S. at 555-56, The court’s determination is not whether the non-moving party “will ultimately prevail,” but whether that party is “entitled to offer evidence to support the claims.” fn re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1420 Gd Cir. 1997) (internal citations and quotation marks omitted). This “does not impose a probability requirement at the pleading stage,” but instead “simply calls for enough facts to raise a reasonable expectation that discovery will reveal evidence of {the necessary element].” Phillips, 515 F.3d at 234 (quoting Twombly, 550 U.S. at 556). “[A] complaint may not be dismissed merely because it appears unlikely that the plaintiff can prove those facts or will ultimately prevail on the merits.” Jed. at 231. B. Rule 12(b)(1) — Lack of Subject Matter Jurisdiction Rule 12(b)(1) of the Federal Rules of Civil Procedure permits a party to move for dismissal of an action for lack of subject matter jurisdiction. Fed. R. Civ. P.

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Pickering v. Teladoc Health, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pickering-v-teladoc-health-inc-ded-2025.