Mobil Coal Producing, Inc. v. Parks

ROSE, Justice,

specially concurring.

I fully agree with the reasoning and holding in the majority opinion that the employee handbook in this case rendered appellee’s employment contract other than an at-will contract. I also agree that the *709evidence supports the trial court’s findings that the appellant/employer failed to comply with the handbook provisions and that, therefore, appellee’s discharge was improper. I write separately because of my concern that the following statement in the majority opinion is not supported by the cited cases:

“Wyoming follows the common-law rule that either party may terminate an employment at will contract (one without a definite term) at any time for any reason or without reason, and that such is not violative of any implied covenant of good faith and fair dealing.” 704 P.2d at 704.

In Rompf v. John Q. Hammons Hotels, Inc., Wyo., 685 P.2d 25 (1984), we reserved a decision on whether termination of employment under an at-will contract might, under certain circumstances, violate an implied covenant of good faith and fair dealing. We observed that a number of courts in other jurisdictions have recently recognized such implied covenants. Mitford v. de Lasala, Alas., 666 P.2d 1000 (1983); Cleary v. American Airlines, Inc., 111 Cal.App.3d 443, 168 Cal.Rptr. 722 (1980); Fortune v. National Cash Register Company, 373 Mass. 96, 364 N.E.2d 1251 (1977); Gates v. Life of Montana Insurance Company, Mont., 638 P.2d 1063 (1982). These courts have looked at the circumstances surrounding the employee’s dismissal and the duration of his employment in determining whether the employee stated a valid claim for breach of contract. Since the employee’s evidence in Rompf v. John Q. Hammons Hotels, Inc. failed to suggest a violation of the good-faith duty imposed upon employment relationships in other jurisdictions, we reached no decision concerning the viability of the doctrine in this state.

The other eases cited in the majority opinion do not address the issue of implied covenants in at-will employment contracts. However, the cited cases of Siebken v. Town of Wheatland, Wyo., 700 P.2d 1236 (1985), and Allen v. Safeway Stores, Incorporated, Wyo., 699 P.2d 277 (1985), as well as the holding and rationale in the case at bar establish that this court is willing to consider the circumstances surrounding an employee’s discharge under a purportedly at-will employment contract.