Stumpp v. Stroudsburg Mun. Auth., 658 A.2d 333 (Pa. 1995). · Go Syfert
Stumpp v. Stroudsburg Mun. Auth., 658 A.2d 333 (Pa. 1995). Cases Citing This Book View Copy Cite
200 citation events (124 in the last 25 years) across 10 distinct courts.
Strongest positive: Lane v. Bonin (pawd, 2011-02-16)
Treatment trajectory · 1995 → 2026 · click a year to view as-of
1995 2010 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Lane v. Bonin (2×) also: Cited as authority (quoted)
W.D. Pa. · 2011 · quote attribution · 2 verbatim quotes · confidence high
the law in pennsylvania is abundantly clear that, as a general rule, employees are at-will, absent a contract, and may be terminated at any time, for any reason or for no reason.
examined Cited as authority (verbatim quote) Solomon v. United States Health Care Systems of Pennsylvania Inc. (2×) also: Cited as authority (quoted)
pactcomplphilad · 2001 · signal: see, e.g. · quote attribution · 2 verbatim quotes · confidence high
it is basic contract law that one cannot suppose, believe, suspect, imagine or hope that an offer has been made. an offer must be intentional, definite, in its terms and communicated; otherwise, no meeting of the minds can occur.
cited Cited as authority (rule) RUTH v. THE HOME DEPOT
E.D. Pa. · 2025 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995).
discussed Cited as authority (rule) Timothy Anstine v. Jerome Adams (2×) also: Cited "see, e.g."
3rd Cir. · 2024 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 3 1995)).
cited Cited as authority (rule) S.C. Graybill v. North York Borough
Pa. Commw. Ct. · 2023 · confidence medium
Auth., 658 A.2d 333, 334 (Pa. 1995); Bolduc, 618 A.2d at 1190 .
examined Cited as authority (rule) Anstine v. Adams (3×) also: Cited "see"
M.D. Penn. · 2023 · confidence medium
Although that would also appear to foreclose an employee’s reliance on an employer’s representation, the Stumpp court went further, commenting that “equitable estoppel has been affirmatively rejected by this Court as an exception to the at-will rule.”69 “Thus, the issue of whether [an employee] detrimentally relied on any promises of the [the employer] is simply not relevant in determining whether [the employee] has a protectable property interest in his employment.”70 unilaterally distributed the handbook and retained the right to unilaterally alter the handbook at-will.” Id. at…
discussed Cited as authority (rule) Mr. Bird's Custom Car Wash Equipment v. Ver-Tech Labs
M.D. Penn. · 2022 · confidence medium
Under Pennsylvania law, “a contract is created where there is mutual assent to the terms of a contract by the parties with the capacity to contract.”106 To establish mutual assent to the contractual terms, a party seeking to an enforce the alleged contract must first show “that an offer has been made.”107 This offer “must be intentional, definite, in its terms, and communicated; otherwise, no meeting of the minds can occur.”108 As such, “it is well established that evidence of preliminary negotiations or a general agreement to enter a binding contract in the 104 Doc. 50 at 5. 105…
discussed Cited as authority (rule) POPE v. WALMART
W.D. Pa. · 2021 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995). “‘Exceptions to this rule have been recognized in only the most limited of circumstances, where discharges of at-will employees would threaten clear mandates of public policy.’” Spyridakis. 398 Fed.Appx. at 799 , quoting Clay v. Advanced Computer Applications, Inc., 559 A.2d 917, 918 (Pa. 1989).
cited Cited as authority (rule) Carroll v. Guardant Health, Inc.
E.D. Pa. · 2021 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995)). 194 Id. (citing Ruzicki v. Catholic Cemeteries Ass’n of Diocese of Pittsburg, 610 A.2d 495, 497 (Pa. Super.
discussed Cited as authority (rule) MILLS v. AFSCME DISTRICT COUNCIL 33
E.D. Pa. · 2020 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995)). 55 Tundo v. Cnty. of Passaic, 923 F.3d 283, 287-88 (3d Cir. 2019). 56 Grayson v. Mayview State Hosp., 293 F.3d 103, 106 (3d Cir.2002). 57 O'Donnell v. Simon, 362 F. App’x 300 , 305 (3d Cir. 2010) (affirming dismissal of attorney’s claim she had a constitutionally protected interest in her employment). 58 ECF Doc.
cited Cited as authority (rule) ROSFELD v. THE UNIVERSITY OF PITTSBURGH - OF THE COMMONWEALTH SYSTEM OF HIGHER EDUCATION
W.D. Pa. · 2020 · confidence medium
Auth., 658 A.2d 333, 334 (Pa. 1995)).
cited Cited as authority (rule) WARDEN v. WOODS SERVICES
E.D. Pa. · 2019 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995).
cited Cited as authority (rule) Donovan v. Pittston Area School District
M.D. Penn. · 2016 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995)).
cited Cited as authority (rule) Heidorn, J. v. Chelten Church
Pa. Super. Ct. · 2016 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995).
cited Cited as authority (rule) Auman, S. v. Family Planning Plus
Pa. Super. Ct. · 2016 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995).
cited Cited as authority (rule) Auman, S. v. Family Planning Plus
Pa. Super. Ct. · 2016 · confidence medium
Auth., 658 A.2d 333, 335 (Pa. 1995).
cited Cited as authority (rule) Damiano v. Scranton School District
M.D. Penn. · 2015 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995)).
cited Cited as authority (rule) Stephen Simcic v. Pittsburgh Water & Sewer Autho
3rd Cir. · 2015 · confidence medium
Auth, 540 Pa. 391 , 658 A.2d 333, 336 (1995).
cited Cited as authority (rule) Kingsbury, Inc. v. GE Power Conversion UK, Ltd.
E.D. Pa. · 2014 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335 (1995).
cited Cited as authority (rule) Kent v. Keystone Human Services
M.D. Penn. · 2014 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335 (1995).
cited Cited as authority (rule) Carrozza, K. v. Childrens Hospital
Pa. Super. Ct. · 2014 · confidence medium
Auth., 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995).” Haun v. Community Health Systems, Inc., 14 A.3d 120, 124 (Pa. Super. 2011).
cited Cited as authority (rule) Diodato v. Wells Fargo Insurance Services, USA, Inc.
M.D. Penn. · 2014 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335 (1995)); see also Fraser v. Nationwide Mut.
discussed Cited as authority (rule) Tyrone Fire Patrol Co. v. Tyrone Borough
Pa. Commw. Ct. · 2014 · confidence medium
See Short; Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 394 , 658 A.2d 333, 334 (1995) (noting that a local agency "does not have the power under law to enter into contracts of employment that contract away the right of summary dismissal, since the power to confer tenure must be expressly set forth in the enabling legislation.”). .
cited Cited as authority (rule) Ransom v. Carbondale Area School District
M.D. Penn. · 2013 · confidence medium
Awth., 540 Pa. 391 , 658 A.2d 333, 335 (1995).
cited Cited as authority (rule) Madziva v. Philadelphia Hous. Auth.
pactcomplphilad · 2013 · confidence medium
Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995) (citations omitted); see also Davenport v. Reed, 785 A.2d 1058, 1063 . .
discussed Cited as authority (rule) Young v. Kisenwether (2×)
M.D. Penn. · 2012 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995)).
discussed Cited as authority (rule) Haun v. Community Health Systems, Inc. (2×)
Pa. Super. Ct. · 2011 · confidence medium
Auth., 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995).
discussed Cited as authority (rule) Woods v. Era Med LLC (2×)
E.D. Pa. · 2010 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335 (1995); see also Scully v. U.S. WATS, Inc., 238 F.3d 497, 505 (3d Cir. 2001) (Pennsylvania law).
discussed Cited as authority (rule) Miller v. Clinton (2×)
3rd Cir. · 2008 · confidence medium
Auth., 658 A.2d 333, 334 (Pa. 1995).
discussed Cited as authority (rule) Miller v. Clinton County (2×)
3rd Cir. · 2008 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995)).
discussed Cited as authority (rule) Knox v. Board of School Directors of Susquenita School District (2×)
Pa. · 2005 · confidence medium
I respectfully disagree with the majority's determination that § 10-1089(c) of the Public School Code of 1949, 24 P.S. § 1-101 et seq., gives appellant "job removal protections" that preclude his dismissal. "[A]s a general rule, Pennsylvania law holds that `employees are at-will, absent a contract, and may be terminated at any time, for any reason or for no reason.'" Pipkin v. Pennsylvania State Police, 548 Pa. 1 , 693 A.2d 190, 191 (1997) (quoting Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391 , 658 A.2d 333, 335 (1995)).
cited Cited as authority (rule) Foxworth v. Pennsylvania State Police
E.D. Pa. · 2005 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335 (1995)).
discussed Cited as authority (rule) Holocheck v. Luzerne County Head Start, Inc.
M.D. Penn. · 2005 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334-35 (1995); Scott, 166 A.2d at 280 ; see also Perri v. Aytch, 724 F.2d 362, 364 (3d Cir.1983); Rosenthal v. Rizzo, 555 F.2d 390, 392 (3d Cir.1977); Cf. Appeal of Gagliardi, 401 Pa. 141 , 163 A.2d 418, 419 (1960) (“A municipality is a creature of the state and possesses only such powers of government as are expressly granted to it and as are necessary to carry the same into effect.”).
discussed Cited as authority (rule) Elmore v. Cleary (2×) also: Cited "see"
3rd Cir. · 2005 · confidence medium
Auth., 658 A.2d 333, 334 (Pa. 1995); Scott, 166 A.2d at 280 ; see also Perri v. Aytch, 724 F.2d 362, 364 (3d Cir. 1983); Rosenthal v. Rizzo, 555 F.2d 390, 392 (3d Cir. 1977).
discussed Cited as authority (rule) Karen Elmore v. Donald Cleary Eugene Turner Kenneth Naugle and Huntington Township (2×) also: Cited "see"
3rd Cir. · 2005 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995); Scott, 166 A.2d at 280 ; see also Perri v. Aytch, 724 F.2d 362, 364 (3d Cir.1983); Rosenthal v. Rizzo, 555 F.2d 390, 392 (3d Cir.1977).
discussed Cited as authority (rule) Sacco v. Township of Butler
Pa. Commw. Ct. · 2004 · confidence medium
The court cited Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 394 , 658 A.2d 333, 334 (1995), for the holding that Commonwealth authorities and agencies do “not have the power under law to enter into contracts of employment that contract away the right of summary dismissal, since the power to confer tenure must be expressly set forth in the enabling legislation.” The court cited Bolduc v. Board of Supervisors of Lower Paxton Township, 152 Pa.Cmwlth. 248 , 618 A.2d 1188 (1992), for the proposition that The Second Class Township Code, Act of May 1, 1933, P.L. 103, as amended, 53 P.…
discussed Cited as authority (rule) Walden v. Saint Gobain Corp.
E.D. Pa. · 2004 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 336 (1995) ("[Ejquita-ble estoppel has been affirmatively rejected by this Court as an exception to the at-will rule.”); Holewinski v. Children’s Hosp. of Pittsburgh, 437 Pa.Super. 174 , 649 A.2d 712, 714 (1994) ("In Pennsylvania, as a general rule, no common law cause of action exists against an employer for termination of an at-will employment relationship.”); see also Walsh v. Alarm Sec.
examined Cited as authority (rule) Demko v. Luzerne County Community College (4×)
M.D. Penn. · 2000 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 334 (1995).
discussed Cited as authority (rule) Lynady v. Community Medical Center (2×)
pactcompllackaw · 2000 · confidence medium
Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995); Niehaus v. Delaware Valley Medical Ctr., 429 Pa. Super. 119, 121 , 631 A.2d 1314, 1315 (1993), citing Scott v. Extracorporeal Inc., 376 Pa. Super. 90, 94 , 545 A.2d 334, 336 (1988); Marsh v. Boyle, 366 Pa. Super. 1 , 530 A.2d 491 (1987).
cited Cited as authority (rule) Permenter v. Crown Cork & Seal Co., Inc.
E.D. Pa. · 1999 · confidence medium
Auth., 540 Pa. 391 , 658 A.2d 333, 335-36 (1995); Paul v. Larikenau Hosp., 524 Pa. 90 , 569 A.2d 346, 348 (1990). 11 .
discussed Cited as authority (rule) Satterfield v. Borough of Schuylkill Haven
E.D. Pa. · 1998 · confidence medium
In Stumpp v. Stroudsburg Municipal Auth., 540 Pa. 391 , 658 A.2d 333 (1995), the Court confirmed that “equitable estoppel has been affirmatively rejected by this Court as an exception to the at-will rule.” Id. at 336.
cited Cited as authority (rule) Hennessy v. Santiago
Pa. Super. Ct. · 1998 · confidence medium
Auth., 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995).
cited Cited as authority (rule) Nearhood v. City of Altoona
Pa. Commw. Ct. · 1998 · confidence medium
Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 392-395 , 658 A.2d 333, 333-335 (1995).
discussed Cited as authority (rule) Short v. Borough of Lawrenceville (2×) also: Cited "see"
Pa. · 1997 · confidence medium
Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391 , 658 A.2d 333, 334-35 (1995).
discussed Cited as authority (rule) Pipkin v. Pennsylvania State Police
Pa. · 1997 · confidence medium
This Court granted allocatur in order to decide whether a probationary state trooper has a sufficient personal or property right in continued employment which would permit him to appeal a decision by the Pennsylvania State Police to terminate his employment to the Commonwealth Court. 1 We preliminarily note that as a general rule, Pennsylvania law holds that “employees are at-will, absent a contract, and may be terminated at any time, for any reason or for no reason.” Stumpp v. Stroudsburg Municipal Authority, *5 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995).
discussed Cited as authority (rule) Geiger v. AT & T CORP.
E.D. Pa. · 1997 · confidence medium
Id The Pennsylvania Supreme Court recently reaffirmed Paul in Stumpp v. Stroudsburg Municipal Authority, in which the court relied on Paul in holding that detrimental reliance on a promise by a government employer “is simply not relevant” in determining whether an employee had a property interest in his employment. 540 Pa. 391 , 658 A.2d 333, 336 (1995).
examined Cited as authority (rule) Luteran v. Loral Fairchild Corp. (3×) also: Cited "see"
Pa. Super. Ct. · 1997 · confidence medium
Thus, the issue of whether an employee detrimentally relied on any promises of the employer is simply not relevant in determining whether the employee [could be discharged].” Stumpp, 658 A.2d at 336 (citation omitted).
discussed Cited as authority (rule) Short v. Borough of Lawrenceville
Pa. Commw. Ct. · 1996 · confidence medium
By its May 31,1995, opinion and order, the trial court held that Borough, through its personnel policy, caused Short to have an “expectation of continued employment with the guarantee that dismissal could occur only after due process of law.” (Trial court opinion at 2.) Therefore, the trial court held that Short was entitled to a hearing concerning her termination and remanded the matter to the Borough to conduct a hearing. 4 Borough appealed to this court. 5 Borough presents two issues on appeal: (1) whether a copy of the policy manual containing provisions for “due process” in connec…
discussed Cited as authority (rule) Werner v. Zazyczny
Pa. · 1996 · confidence medium
We also preliminarily note that as a general rule, Pennsylvania law holds that “employees are at-will, absent a contract, and may be terminated at any time, for any reason or for no reason.” Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391 , 658 A.2d 333, 335 (1995).
discussed Cited as authority (rule) Luteran v. Fairchild Weston Systems Inc.
pactcomplmontgo · 1996 · confidence medium
“The law in Pennsylvania is abundantly clear that, as a general rule, employees are at-will, absent a contract, and may be terminated at any time, for any reason, or for no reason.” Stumpp v. Stroudsburg Municipal Authority, 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995); Highhouse v. Avery Transportation, 443 Pa. Super. 120, 124 , 660 A.2d 1374, 1376 (1995).
Retrieving the full opinion text from the archive…
Clarence L. STUMPP, Appellee,
v.
STROUDSBURG MUNICIPAL AUTHORITY, Appellant
Supreme Court of Pennsylvania.
May 16, 1995.
658 A.2d 333
1995 Pa. LEXIS 324
Bernard M. Billick, Stroudsburg, for Stroudsburg Mun. Authority., Ronald J. Karasek, Bangor, for Clarence Stumpp.
Nix, Flaherty, Zappala, Cappy, Castille, Montemuro.
Cited by 75 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: bottom 72%
Citer courts: Philadelphia County Court of C… (1) · W.D. Pennsylvania (1)

OPINION OF THE COURT

CAPPY, Justice.

The question in this appeal is whether appellee Clarence L. Stumpp, as a public employee who is neither protected by civil service regulations nor covered by any collective bargaining[*393] agreement, has the right to notice and a hearing as a result of his dismissal. Because we find that the Commonwealth Court erred in determining that Appellee had a “property right” in his employment, we reverse.

Appellee was an employee of the Stroudsburg Municipal Authority (“Authority”) as manager of its water treatment plant. On February 7, 1992, the Authority sent a letter to Appellee indicating that the Authority was unhappy with his job performance and that Appellee would no longer be able to remain serving in the capacity as Manager of the Authority. The Authority also indicated that it would hold a position for Appellee as Plant Operator, a lesser job. The letter stated, “if you wish to retain this position until you retire, please advise the Authority Board, so that we can schedule an executive session to discuss the salary.” Appellee accepted the position. Notwithstanding these events, Appellee’s employment was terminated on September 17, 1992.

On January 29, 1993, Appellee filed a request for review of the Authority’s decision, characterizing the decision to terminate as a “local agency adjudication.” [1] The Authority then filed preliminary objections to Appellee’s appeal, asserting lack of subject matter jurisdiction pursuant to Pa.R.Civ.P. 1028(a)(1). The basis for the Authority’s objection was that Appellee’s termination was not an “adjudication” as defined by Local Agency Law, 2 Pa.C.S. § 101. According to § 101, an adjudication is defined in relevant part as:

Any final order, decree, decision, determination or ruling by an agency affecting personal or property rights, privileges, immunities, duties, liabilities or obligations of any or all of the parties to the proceeding in which the adjudication is made....

[Emphasis added]. The Authority argued that Appellee’s termination was not an adjudication because Appellee was an at-will employee and therefore had no property interest or right in continued employment with the authority. The Au[*394] thority also argued that it had no power to enter into a contract for employment, absent legislation authorizing it to do so. The trial court agreed with the Authority on both issues and dismissed Appellee’s claim for lack of subject matter jurisdiction.

The Commonwealth Court reversed, finding that as a result of the February 7, 1992 letter, Appellee had an “implied” contract for employment and therefore had a protectable property right. The court also held that the Authority had the power to enter into such a contract. The Court also believed that Appellee’s argument that the doctrine of “equitable estoppel” barred his termination was a question that should be considered at a termination hearing. Finally, the court determined that a termination letter sent to Appellee was in fact an “adjudication” from which Appellee could appeal, since it affected Appellee’s property rights. Accordingly, the court remanded the matter back to the Court of Common Pleas so that Appellee could be afforded the proper notice and hearing related to his termination.

The Authority now contends that the Commonwealth Court erred in determining that the Authority had the power to enter into a contract for employment and in finding that Appiellee had a protectable property interest in the form of a contract for employment. We agree with the Authority and reverse.

As an initial matter, the Authority simply does not have the power under law to enter into contracts of employment that contract away the right of summary dismissal, since the power to confer tenure must be expressly set forth in the enabling legislation. Scott v. Philadelphia Parking Authority, 402 Pa. 151, 166 A.2d 278 (1960); Bolduc v. Board of Supervisors, 152 Pa.Commw. 248, 618 A.2d 1188 (1992), appeal denied, 533 Pa. 662, 625 A.2d 1195 (1993). As this Court stated in Scott:

Without more, an appointed public employee takes his job subject to the possibility of summary removal by the employing authority. He is essentially an employee-at-will____
[*395] Tenure in public employment, in the sense of having a claim to employment which precludes dismissal on a summary basis is, where it exists, a matter of legislative grace....
[Wjhere the legislature has intended that tenure should attach to public employment, it has been very explicit in so stating____

402 Pa. at 151-157, 166 A.2d at 280-282. This holding has not been abrogated by either this Court or by the legislature. Appellee presents no case law that refutes the explicit holding of this case. In this regard, we find the Commonwealth Court’s reliance on Pavonarius v. City of Allentown, 157 Pa.Commw. 116, 629 A.2d 204 (1993), for the proposition that the Authority was empowered to enter into a contract for employment with Appellee, to be incorrect. The Commonwealth Court cited the following language in Pavonarius: “[a]n individual employed by a local agency is an at will employee and does not enjoy a property right in her employment unless she has a expectation of continued employment guaranteed by contract or statute.” Stumpp v. Stroudsburg Municipal Authority, 166 Pa.Commw. 554, 558, 646 A.2d 734, 736 (1994) (emphasis in original), citing Pavonarius, 157 Pa.Commw. at 121, 629 A.2d at 207. In Pavonarius, a wrongful termination suit was brought by a police officer whose employment was governed by civil service regulations. Thus, the court never even had to reach the question of whether the municipality had the power to enter into an employment contract with the terminated employee, since the employee’s employment rights were conferred by statute. The above-quoted language cannot be construed to abrogate the general rule that municipalities are not permitted to enter into employment contracts absent authorizing legislation. Accordingly, there is nothing in Pavonarius to contradict Scott or the principle that municipal entities lack the authority to confer employment tenure by contract.

Although we find that Scott clearly rejects Appellee’s position that he was entitled to a termination hearing, since we[*396] find that no contract could have been conferred upon Appellee, we believe we are also compelled to address the Commonwealth Court’s opinion that there was a contract between the Authority and Appellee in this case.

The law in Pennsylvania is abundantly clear that, as a general rule, employees are at-will, absent a contract, and may be terminated at any time, for any reason or for no reason. See Geary v. United States Steel Corp., 456 Pa. 171, 319 A.2d 174 (1974); Fawcett v. Monongahela Ry. Co., 391 Pa. 134, 137 A.2d 768 (1958); Krajsa v. Keypunch, Inc., 424 Pa.Super. 230, 622 A.2d 355 (1993). Here, Appellee claims that the letter from the Authority constituted a contract for employment “until he retired.” We find this contention to be without merit. It- is basic contract law that one cannot suppose, believe, suspect, imagine or hope that an offer has been made. An offer must be intentional, definite, in its terms and communicated; otherwise, no meeting of the minds can occur. Morosetti v. Louisiana Land and Exploration Co., 522 Pa. 492, 494, 564 A.2d 151, 152 (1989). In the instant case, it is very questionable whether the Authority’s words could be reasonably construed to be an offer for a definite term of employment, with all the attendant rights and privileges that accompany contractual employment. Moreover, even if there was an “offer” for contractual employment which could be accepted, the requisite consideration to support the contract is missing. The law is clear that an employee must give his employer “additional” consideration other than the services for which he was hired. Additional consideration exists when an employee affords his employer a substantial benefit other than the services which the employee is hired to perform, or when the employee undergoes a substantial hardship other than the services which he is hired to perform. Darlington v. General Elec., 350 Pa.Super. 183, 201, 504 A.2d 306, 315 (1986). Here, the Authority’s letter of February 7, 1992, makes clear that Appellee was being fired from his position as Manager and was offered the position of Plant Operator as a substitute.[*397] Thus, contrary to Appellee’s assertion that he “gave up” something of value in accepting the demotion, Appellee’s only-alternative was to be unemployed.

Moreover, the Commonwealth Court’s suggestion that Appellee’s “detrimental reliance” on the offer of employment as a Plant Operator could provide Appellee with a protectable property interest in his employment is wholly without basis in fact or law. As noted above, Appellee did not rely to his “detriment” on any promises of the Authority; rather, he was fortunate to be offered another position with the Authority. More importantly, equitable estoppel has been affirmatively rejected by this Court as an exception to the at-will rule. In Paul v. Lankenau Hospital, 524 Pa. 90, 569 A.2d 346 (1990), we held that “[t]he doctrine of equitable estoppel is not an exception to the employment at will doctrine. An employee may be discharged with o[rj without cause, and our law does not prohibit firing an employee for relying on an employer’s promise.” Id. at 95, 569 A.2d at 348. Thus, the issue of whether Appellee detrimentally relied on any promises of the Authority is simply not relevant in determining whether Appellee has a protectable property interest in his employment.

Accordingly, we reverse the order of the Commonwealth Court.

ZAPPALA, J., concurs in the result.

MONTEMURQ, J., is sitting by designation.

1

. If an adjudication under the Local Agency Law takes place, the affected individual is entitled to notice and hearing prior to termination.