Stumpp v. Stroudsburg Municipal Authority

RODGERS, Senior Judge,

dissenting.

I respectfully dissent. In Bolduc v. Board of Supervisors, 152 Pa.Commonwealth Ct. 248, 618 A.2d 1188 (1992), petition for allowance of appeal denied, 533 A.2d 662, 625 A.2d 1195 (1993), a Township manager accepted a reclassification to the part-time position of special projects administrator at a salary of $30,000 per year and health benefits, beginning January 1990. In March, 1991, the Township agreed to continue his employment until December 31, 1991. In May, 1991, the township discharged him because he refused to relinquish his health benefits. This Court held that the township acted beyond its power by entering into the employment contract with Bolduc and contracting away the right to summarily dismiss an employee. This Court felt itself bound by the authority of Scott v. Philadelphia Parking Authority, 402 Pa. 151, 166 A.2d 278 (1960), where the Pennsylvania Supreme Court decided that the broad general powers granted the Authority to make contracts of every name and nature did not include the power to contract away the right of summary *561dismissal as the power to confer tenure by contract must be expressly set forth in the enabling legislation.

Bolduc held that, in the absence of civil service tenure or a collective bargaining contract, public employees such as Bolduc are employees at will subject to summary dismissal without hearing. The court also said it could not consider Bolduc’s claim of equitable estoppel because he had not raised it before, nor properly pleaded its elements.

Based upon this dictum in Bolduc, the majority finds that Stumpp may be entitled to rely upon the doctrine of equitable estoppel in this case. However, in the case of Paul v. Lankenau Hospital, 524 Pa. 90, 95, 569 A.2d 346, 348 (1990), the Supreme Court held that “[t]he doctrine of equitable estoppel is not an exception to the employment at-will doctrine. An employee may be discharged with our [sic] without cause, and our law does not prohibit firing an employee for relying on an employer’s promise.”

The petitioners in Williams v. Philadelphia Housing Authority, 834 F.Supp. 794 (E.D.Pa.1993), claimed the language in Bolduc supported the equitable estoppel exception. In rejecting this claim the court said:

Williams’ reliance on Bolduc is without merit. First, the court in Bolduc did not reach the equitable estoppel inquiry, and the opinion concerning equitable estoppel must be treated as mere dictum. Even so, Pennsylvania’s Supreme Court has not addressed Bolduc’s equitable estoppel exception and is not [sic], therefore, sufficient to supplant or supplement the Pennsylvania at-will employment laws.

Williams, 834 F.Supp. at 798 (footnote omitted).

Stumpp was an employee at-will. See Scott. “[Allowing an employee to claim equitable estoppel where the law declares that no implied contract exists would simply undercut the rule that an action for wrongful discharge does not exist in an at-will employment relationship.” Ruzicki v. Catholic Cemeteries Assoc. of the Diocese of Pittsburgh, 416 Pa.Superior Ct. 37, 44, 610 A.2d 495, 498 (1992).

*562In my opinion, Pavonarius v. City of Allentown, 157 Pa.Commonwealth Ct. 116, 629 A.2d 204 (1993), is inapposite in this case, because the plaintiff police officer had civil service tenure.

I would affirm the decision of the trial court.