(dissenting in part). I agree that, under Toussaint v Blue Cross & Blue Shield of Michigan, 408 Mich 579; 292 NW2d 880 (1980), an employer can avoid the perils of a jury review of its cause determination by providing for alternative methods of dispute resolution. I do not agree with the implicit holding of the majority opinion that any alternative method of dispute resolution will preclude a jury review of the cause determination.
The Toussaint Court explained the need for jury review of the employer’s cause determination as follows:
A promise to terminate employment for cause only would be illusory if the employer were permitted to be the sole judge and final arbiter of the *501propriety of the discharge. [Toussaint, supra, p 621.]
That point was treated as axiomatic by the Court and so stated without authority or further explanation. I believe and submit, however, that the reason the Toussaint Court found such a promise to be illusory is that it fails to incorporate even elementary procedural fairness in the determination of cause. The Toussaint Court thereby acknowledged that cause necessarily incorporates both substantive and procedural aspects.
Obviously, the most significant element of procedural fairness lacking in a final and binding determination of cause by the employer is impartiality. Since the grievance council members in this instance were elected "from the ranks,” I am inclined to believe that they sufficed, at least initally, as impartial arbiters. However, I do not believe that impartiality is an immutable characteristic. Proceedings which do not incorporate other elements of procedural fairness may easily manipulate an otherwise impartial arbiter and grossly distort the outcome. Thus, unlike the majority, I believe that a promise of discharge for cause may be illusory even if applied by an apparently impartial council of arbiters.
Unlike the majority, I do not find Frazier v Ford Motor Co, 364 Mich 648; 112 NW2d 80 (1961), dispositive. The deference exercised by the Frazier Court toward the grievance procedure employed therein was derived not from judicial indifference, but from respect for the statutorily mandated collective bargaining procedure. Here there is no collective bargaining agreement. Moreover, even if the deferential standard for collective bargaining agreements is used, it is more accurately set forth in Breish v Ring Screw Works, 397 Mich 586; 248 *502NW2d 526 (1976). Under Breish, the procedure employed in final and binding arbitration must be "adequate to provide a fair and informed decision.” Breish, supra, p 601.
As the majority concedes, the plaintiff in this instance was denied counsel and denied presence during the proceedings of the grievance council. The plaintiff had no right to cross-examination, no record was kept of the proceedings and the employee was given only a conclusory, one-sentence decision by the council. In addition, the employer appears to have violated its own procedures by allowing Gerald Guinane to testify.1
While I cannot say that any one of these would render the procedure defective, the combined effect was clearly inadequate to provide a fair and informed decision. This was not the "hearing” promised in the employee handbook, but an inquisition. The procedure employed may well have been manipulated by the employer to transform an impartial jury of the plaintiff’s peers into a misled mob.
In sum, the employer was under no duty to do so, but nevertheless established a policy of discharge for "cause.” Having done so, Toussaint requires that the employer adhere to that policy. A promise of discharge for cause which is not illusory implicitly embraces both procedural and substantive protections. Here the procedures employed by the employer were plainly inadequate for a reliable determination of cause. I do not, of *503course, hold that the employer thereby violated its policy. I do hold that these procedures cannot insulate the employer’s determination from judicial review. I would therefore affirm the trial court’s denial of summary disposition on the claim for breach of employment contract.
Paragraph 2B of the Grievance Guide under "hearings” provides:
No one except you, your Supervisor, your Department Head, the witnesses and the Grievance Council Advisor may appear before the Council.
The plaintiff alleges that Guinane was none of these, but instead the "decision maker at step 3.” If so, the majority has essentially misrepresented the plaintiff’s claim as merely one alleging that a disproportionate amount of time was spent with one witness.