Doyle v. Holy Cross Hospital

Mary Doyle (plaintiff) was a nurse employed by Holy Cross Hospital (hospital) (defendant) beginning in 1960. In 1971, the hospital issued an employee handbook that specified certain criteria for identifying which employees would be affected in the event of an economically driven layoff. In 1983, the hospital added a new policy, which stated that the personnel policies contained in the handbook were subject to change from time to time and did not constitute an implied or express contract. The new policy also provided that the hospital could terminate the employment relationship at any time, with or without notice. In 1991, the hospital discharged Doyle, along with three other nurses who were also employed before the 1983 disclaimer, without following the economic separation provisions of the 1971 handbook. Doyle and the other nurses sued the hospital for breach of contract. The trial court granted the hospital’s motion to dismiss, and the nurses appealed. The appellate court reversed, and on remand, the trial court entered another order of dismissal. The nurses appealed again, and again the appellate court reversed, holding that the hospital’s modification of the handbook terms was not enforceable against the nurses because it was not supported by consideration. The Illinois Supreme Court then allowed the hospital’s petition for leave to appeal.