Pine River State Bank v. Mettille

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Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn. 1983).

Facts: Plaintiff was hired (at-will) as a loan officer. After multiple serious errors, he was fired without following the procedure of notice laid out in the employee handbook.

Issue: Did the employee handbook constitute a contract between Plaintiff and Defendant?

Holding: Yes, and Defendant violated it by not providing notice for termination, as provided in the handbook.

Rule:

  • Employment for unspecified term is at will employment--a unilateral contract
    • Consideration is the continued performance by the employee
  • The presumption is that employment is at will (it may terminate at any time)
    • Exceptions:
      • If an employment handbook specifically state procedures for dismissal
    • Employer conduct or assurances in the employment relationship creates a contract to not fire except for good cause the employment is no longer at will.