¶ 67. dissenting. The majority’s solution to the ambiguity inherent in 24 V.S.A. § 1233 — which provides that a town manager shall hold office “at the will of’ the selectmen who “may remove him at any time for cause” — is to conclude that “at *305the will of’ does not mean what we think it means. In the majority’s view, the phrase was not understood by its drafters “in the modern conventional sense” of an employment terminable at any time for any reason. Ante, ¶ 20. In support of this proposition, the majority claims that the at-will concept was not widely employed in Vermont law when the statute was enacted, and that “the Legislature may have viewed the language as having a different meaning from what it means today.” Ante, ¶ 14. In contrast to the relative dearth of Vermont law employing the “at will” language, the majority cites a number of early'Vermont cases and statutes using the alternative phrase “at the pleasure of.”
¶ 68. The majority thus concludes that the “at will” language of the statute, enacted six years before Mullaney, was actually meant to convey something altogether different, to wit, that “it is the selectboard — and no other authority — that may remove the town manager and that the selectboard has the discretion to initiate termination.” Ante, ¶ 20. Thus, the majority holds that the “for cause” language of the statute must control, and that — contrary to the conclusion of the trial court here — plaintiff was terminable only for cause.
¶ 69. With respect, the majority’s assertion that the phrase “at the will of’ is a “modern” construct that had an entirely different meaning in 1917 does not withstand historical scrutiny. As explained below, the “at will” language had precisely the same legal éffect then as it does now — across the nation and in Vermont in particular. Thus, its accepted and conventional meaning must be harmonized with the rest of the statute — not read out of it — to serve a more plausible legislative purpose, one in which the “for cause” language does not supersede the at-will provision but appropriately qualifies it.
¶ 70. It is important to recognize, at the outset, that “at the will of’ or “at will” employment was a legal phrase and construct widely used in the United States not only in the early decades of the twentieth century, when the statute at issue here was enacted, but in the century preceding it. Indeed, in the last half of the nineteenth and early years of the twentieth centuries, courts throughout the country employed the phrase precisely as we do today, to convey the idea of an employment terminable at any time for any reason as opposed to one terminable only for cause. Although far too numerous to cite in their entirety, these early decisions include Gibbs v. City of Manchester, 61 A. 128, 129 (N.H. *3061905) (holding that, under state law, “the [police] commissioners are not authorized to remove police officers at will, but for good and sufficient cause, and after due hearing” (emphasis added)); State ex rel. Fitzgerald v. Mayor of New Brunswick, 1 A. 496, 501 (N.J. 1885) (noting that the “power of removal” of police officers “may exist in some cities at the will of some municipal officer or body of officers” while in others the removal is only “for cause” (emphasis added)); People ex rel. Wheeler v. Cooper, 57 How. Pr. 416,_(N.Y. Sup. Ct. 1879) (holding that mayor’s “power ... to remove is for cause, after an opportunity to be heard,” and observing that not allowing a hearing would render the “safeguard ... a hollow device and a sham; because a removal could actually be made at the will of the removing power” (emphasis added)); Smith v. Bryan, 40 S.E. 652, 653-54 (Va. 1902) (observing that “the absolute power of removal” is “a tenure at will” as opposed to one “for cause” (emphasis added)).12
¶ 71. Reflecting the nearly universal understanding of the at-will concept, late nineteenth- and early-twentieth-century commentators on the law of municipal corporations routinely utilized the phrase in its “modern” sense in characterizing the tenure of municipal officers. See, e.g., 2 J. Dillon, Commentaries on the Law of Municipal Corporations § 473, at 791 (5th ed. 1911) (“With respect to the tenure or duration of a public employment, the general rule is that where the power of appointment is conferred in general terms . . . the power of removal, in the discretion and at the will of the appointing power and without notice or a hearing, is implied . . . .” (second emphasis added)); 2 E. McQuillan, Municipal Corporations § 558, at 1229 (1911) (“Unless the law otherwise provides, if the officer is appointed . . . and no definite term is prescribed, he holds at the will or pleasure of his superior or the appointing . . . authority ...” (emphasis added)).
¶ 72. Thus, as one more recent court — recounting the history of the at-will employment concept — has concluded: “By the arrival of the twentieth century, the at-will doctrine was well-established throughout the United States and served to reinforce turn-of-the-century ideas concerning laissez-faire economics and *307freedom to contract.” Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1041 (Utah 1989); see also Bernard v. IMI Sys., Inc., 618 A.2d 338, 343 (N.J. 1993) (noting that, by 1913, most jurisdictions had explicitly adopted at-will employment rule).
¶ 73. In light of the foregoing, it simply strains credibility to maintain that an employment characterized as “at the will of’ the appointing power lacked the same legal meaning and effect in early-twentieth-century Vermont that it had throughout the rest of the United States. We need not, however, merely surmise how the phrase was understood here from its broad acceptance elsewhere. For it was certainly in use in Vermont prior to the enactment of the town manager statute in 1917, the majority’s claim to the contrary notwithstanding.
¶ 74. In Rutter v. Burke, 89 Vt. 14, 93 A. 842 (1915), this Court considered the Burlington city council’s authority to remove certain water commissioners under a charter provision empowering the council to remove its appointees “for such causes of incapacity, negligence or bad conduct as to it shall seem sufficient.” Id. at 17, 93 A. at 844. The city claimed that the charter gave the council unfettered authority to remove appointees “in its discretion, or at its pleasure.” Id. at 26, 93 A. at 848. We rejected the claim, however, relying on the plain language of the charter, which clearly limited the removal power to the enumerated causes, as well as the “well established rule that an authority to remove for cause excludes the power to remove at will.” Id. (emphasis added). Rutter relied, in turn, on a number of out-of-state decisions in support of this “well established” proposition; all were decided decades earlier, and all employed the familiar “at will” terminology. Id. at 26-27, 93 A. at 848; see Miles v. Stevenson, 30 A. 646, 648 (Md. 1894) (contrasting statute at issue, which expressly required cause for removal, from others where “there is no limit fixed to the term of the office and the appointee holds merely at the will of the appointing power” (emphasis added)); Speed v. Common Council, 57 N.W. 406, 410 (Mich. 1894) (noting that where provision provides that officers may be “removed for cause” it “excludes the power to remove at will” (emphasis added)); State ex rel. Gallagher v. Brown, 57 Mo. App. 199, 1894 WL 2191, at *2 (1894) (noting that law generally provides for two ways of removing a public officer, “for cause” and “without cause, at will” (emphasis added)).
¶ 75. Thus, plaintiff’s argument, and the majority’s conclusion, that “at the will of’ as used in § 1233 did not mean the same *308thing in Vermont in 1917 as it does today is entirely unpersuasive. Equally futile is plaintiffs broader historical argument that, as part of the general “progressive” reform movement of the early twentieth century, the town manager form of government was designed to “insulate[]” the town manager from the shifting “political winds” that might effect a change in local selectboards. This goal of progressive municipal reform, plaintiff argues, lends general support to the proposition that, in enacting § 1233, the General Assembly intended to require good cause for removal rather than allow removal at the whim of the current selectboard.
¶ 76. Apart from the absence of any evidence showing that this was, in fact, the driving ideal behind the statute, however, the argument — taken on its own terms — is overly simplistic and unreliable. Historians have long noted the underlying social, economic, and especially political complexities that animated “progressivism” as a movement. See, e.g., D. Rogers, In Search of Progressivism, 10 Revs. in Am. Hist. 113, 114 (1982) (noting “the emergence of a pluralistic reading of progressive politics, in which the fundamental fact of the era is not reform in any traditional sense of the term, but the explosion of scores of aggressive, politically active pressure groups into the space left by the recession of traditional political loyalties”). Nowhere was this more true than in the area of municipal reform, where scholars have shown that innovations such as the commission or town manager form of city government were pushed through by economic and social elites to wrest power from local ward bosses and centralize control in professional “experts” and upper-class businessmen. See, e.g., S. Hays, The Politics of Reform in Municipal Government in the Progressive Era, 55 Pac. N.W. Q. 157, 159, 161-62, 167 (1964) (noting that business community was “overwhelming force behind both commission and city-manager movements,” that their objection to status quo was not to “corruption per se” but a system that allowed lower-class and immigrant groups to dominate local politics, and that they “hoped . . . reform would enable them to increase their political power” and serve “as vehicles whereby business and professional leaders moved directly into the inner circles of government”). Confronted with growing numbers of enfranchised, lower-class urban immigrants, the goal of progressive reformers was thus not to remove political influence from municipal government, but to keep it in the right hands. See id. at 162 (concluding that municipal reform movements “constituted *309an attempt by upper-class, advanced professional and large business groups to take formal political power from the previously dominant lower- and middle-class elements so that they might advance their own conceptions of desirable public policy”).
¶ 77. It is hardly surprising, therefore, to find statutes authorizing cities with a town manager form of government to remove the manager at will, or to find courts upholding such provisions as consistent with that form of governance. See, e.g., Curry v. City of Cambridge, 217 N.E.2d 740, 742 (Mass. 1966) (observing that “powers and duties of the city manager are so closely coordinated with those of the city council in the general management of the city’s affairs that the Legislature manifestly could not have intended that its incumbent should be allowed to remain in office even for a very short period of time against the city council’s wishes”); Note, City Government, 38 B.U. L. Rev. 419, 456, 463-64 (1958) (reviewing history of “city manager form of government” in New England, discussing its statutory bases, and noting that town managers are generally removable at pleasure of city council under statutory provisions in Massachusetts, New Hampshire, and Connecticut).
¶ 78. Thus, there is no historical basis to conclude that the legislative purpose in enacting § 1233 was to insulate the town manager from local politics by ensuring that his or her removal was not at the will of the selectboard but solely for cause.
¶ 79. We are thus squarely confronted with the need to reconcile two seemingly contradictory concepts — removal “for cause” and “at will” — in one statute. We are not, however, entirely without guidance in this regard. A series of decisions construing equally venerable Massachusetts laws regulating the removal of municipal appointees provide a useful starting point. In O’Dowd v. City of Boston, 21 N.E. 949 (Mass. 1889), the high court of Massachusetts was confronted with a statute authorizing a city board to remove ferry workers “for such cause as they may deem sufficient, and shall assign in their order for removal.” Id. at 949 (quotation omitted). The plaintiff claimed that the statute required that removal be for cause, while the city maintained that dismissal was purely at the pleasure of the board.
¶ 80. The Massachusetts court noted the potential ambiguity in the statute that appeared to vest broad removal discretion in the board and require removal for “cause.” Id. at 950. It resolved the issue by holding “[t]he intention of the statute ... to be to *310qualify a removal at pleasure by requiring a record to be made of the cause.” Id. (emphasis added). This construction, the court observed, ensured both “the vigor and efficiency of [public] administration” served by the at-will doctrine, while simultaneously discouraging — through the requirement of public disclosure — removals against public policy, i.e., “for a cause for which it could not lawfully be made.” Id. Armed with at least a record of the reason for removal, the employee might ultimately appeal to the “court” of public opinion. Id.
¶ 81. The Massachusetts court reached the same result in applying a similar municipal provision in Ray v. Mayor of Everett, 103 N.E.2d 269 (Mass. 1952). There, a city charter provided that officers appointed by the mayor “may be removed by the mayor for such cause as he shall deem sufficient and shall assign in his order of removal.” Id. at 271. The court held that the mayor had complied with the statute by stating the “cause” for removal in general terms, and was not required to bring specific charges or afford the employee a hearing, leaving it instead to the “conscience and sound judgment” of others, rather than the law, as to whether the cause was sound. Id. at 272.
¶ 82. In Fabrizio v. City of Quincy, 404 N.E.2d 675 (Mass. App. Ct. 1980), the same issue was revisited in a more modern statute to the same effect, providing that a mayor may remove a department head “by filing a written statement with the city clerk setting forth in detail the specific reasons therefor.” Id. at 676 (quotation omitted). The court held that the mayor had complied with the statute and that, contrary to the plaintiffs claim, he was not afforded a “property” interest under the statute entitling him to a hearing and other due process protections. Id. at 677.
¶ 83. Although these provisions obviously differ from § 1233, they nevertheless suggest a useful general approach to reconciling the latter’s seemingly conflicting terms by qualifying the town manager’s “at-will” tenure in office with a requirement that the selectboard state the “cause” for removal. As suggested in O’Dowd, this approach preserves the efficiency of the at-will doctrine in municipal employment while also providing at least a basis for the town manager — and ultimately the public — to judge the wisdom and merits of the decision. Thus understood, plaintiff here and other town managers enjoy no “protectable property interest” in their employment entitling them to any process other than a clear statement from the selectboard as to *311the cause of their removal. Brennan v. Town of Colchester, 169 Vt. 175, 179-80, 730 A.2d 601, 605 (1999).
¶ 84. Here, the record surrounding the selectboard’s removal decision and its express statement that plaintiffs termination was for actions that were “directly against the will of the board” and further “misrepresented” by plaintiff to the board, was sufficient to state the “cause” for his removal and thereby satisfy the statute. Accordingly, I would affirm the summary judgment of the trial court in favor of the Town.
¶ 85. Although I find the majority’s reasoning to be unpersuasive, this is clearly a challenging case. An ambiguous law, nearly a century after its enactment, presents a unique problem for judicial construction. Contrary to the conclusion of the majority, however, the difficulty is not understanding the statute’s conflicting terms; it is understanding how they relate. While we cannot hope to know precisely how the drafters would have answered this question, we can — and must — at least attempt to harmonize the language they actually used. Qualifying the Town’s otherwise absolute removal authority under the “at will” provision of the statute by requiring that it set forth the “cause” for removal offers, in my view, a workable resolution. While it may or may not precisely mirror the drafters’ intent, it is at least more faithful to their language. Accordingly, I respectfully dissent.
That the at-will employment language and concept have even earlier roots maybe seen in such cases as Avery v. Inhabitants of Tyringham, 3 Mass. 160 (1807), where the court held, as to the local minister, that if “his office be at mil" the parish “can remove him at their pleasure” rather than “for good cause.” Id. at 178 (emphasis added).