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McDonald v. Mobil Coal Producing, Inc.

Supreme Court of Wyoming
820 P.2d 986 (Wyo. 1991)


Facts

McDonald (plaintiff) was an employee of Mobil Coal Producing (Mobil) (defendant). He signed an employee at-will contract when he started working there. Amid rumors that McDonald had sexually harassed a female coworker, he asked his supervisor about the rumors and was told to “do his job and not worry about what had been said.” Subsequently, presumably on account of the rumors, Mobil gave McDonald the option of either resigning or being fired. McDonald chose to resign and brought this suit claiming breach of contract based on his employee handbook. The handbook stated in plain text that it was a guide to Mobil’s policies and procedures and not an employment contract. However, the handbook also stated that “individual consideration” and “free and open communications” would be used to resolve differences between employee and supervisor, and so unionization was not necessary. The handbook also contained general disciplinary procedures. McDonald alleged that the handbook thus modified his employee at-will status and created an employment relationship under which McDonald could only be fired for cause. Mobil on the other hand, claimed that McDonald’s employment was at-will and that the handbook did not modify that relationship. The trial court granted summary judgment in favor of Mobil. The Supreme Court of Wyoming reversed the summary judgment and remanded for further proceedings. The Supreme Court of Wyoming then granted Mobil’s motion for rehearing.

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Holding and Reasoning (Golden, J.)

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Dissent (Cardine, J.)

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