Wednesday, December 25, 2013

Dore v. Arnold Worldwide, Inc. case brief

Dore v. Arnold Worldwide, Inc. case brief summary
139 P.3d 56 (Cal. 2006)

CASE SYNOPSIS
Plaintiff former employee sued defendant former employer in connection with his termination, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and fraud. The trial court granted summary judgment for the employer on the ground that the employee could not establish an agreement that his employment was terminable only for cause. The Court of Appeal of California reversed. The employer sought further review.

CASE FACTS
The employee signed an employment letter containing an at-will provision and defining "at will" as the right to terminate the employment "at any time."

DISCUSSION

  • In reversing the decision for the employee, the California Supreme Court disagreed with the argument that the verbal formulation "at any time" in the termination clause of an employment contract was per se ambiguous merely because it did not expressly speak to whether cause was required. 
  • Rather, such a formulation ordinarily entailed the notion of "with or without cause." 
  • Further, the letter at issue was unambiguous, despite its failure to state whether cause was required. 
  • The letter plainly stated that employment "at will," at term that, when used in an employment contract, normally conveyed an intent that employment could be ended by either party at any time without cause. 
  • Thus, no triable issues of fact existed as to breach of contract and breach of the implied covenant of good faith and fair dealing. 
  • The employer was also entitled to summary judgment as to promissory fraud because the employee produced insufficient evidence of reliance.
CONCLUSION
The court reversed the judgment of the Court of appeal.

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