at-will employment doctrine (Ohio) · Go Syfert
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at-will employment doctrine in Ohio

33 Ohio opinions name it 3 courts 1989–2026 6 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Greeley v. Miami Valley Maintenance Contractors, Inc.green
ohio · 1990 · cited in 14 Ohio opinions naming this issue, 1999–2026
2 sentences

2008Departing from the traditional at-will employment rule, the Supreme Court held that "the right of employers to terminate employment at will for `any cause' no longer includes the discharge of an employee where the discharge * * * contravenes public policy." Id. at paragraph two of the syllabus.

2007Mers v. Dispatch Printing Co. (1985), 19 Ohio St.3d 100 , 483 N.E.2d 150 , paragraph one of the syllabus. {¶ 17} In Greeley v. Miami Valley Maintenance Contr, Inc. (1989), 49 Ohio St.3d 228 , 551 N.E.2d 981 , the Ohio Supreme Court first recognized that there is an exception to the at-will employment doctrine when an employee is discharged or disciplined for a reason that violates the clear public policy of Ohio.

214
Benjamin v. Pipolygreen
ohioctapp · 2003 · cited in 2 Ohio opinions naming this issue, 2005–2005
2 sentences

2005See Benjamin v. Pipoly (2003), 155 Ohio App.3d 171 , 183 (dealing with the Superintendent of Insurance and liquidators of insolvent insurers).

2005See Benjamin v. Pipoly (2003), 155 Ohio App.3d 171 , 183 , 2003 Ohio 5666, 800 N.E.2d 50 (dealing with the Superintendent of Insurance and liquidators of insolvent insurers).

22
Collins v. Rizkanagreen
ohio · 1995 · cited in 5 Ohio opinions naming this issue, 2003–2020
2 sentences

2013Collins v. Rizkana, 73 Ohio St.3d 65, 70 (1995). {¶ 22} As to the issue of clarity, the question is whether there is a clear public policy to protect a specific public interest sufficient to justify an exception to the at-will employment doctrine.

2003If the nonmoving party fails to meet this burden, then summary judgment is appropriate. {¶ 22} We begin with an issue not addressed by the trial court. 3 In Ohio, the courts adhere to the at-will-employment doctrine, which refers to the *522 traditional rule that a “general or indefinite hiring is terminable at the will of either party, for any cause, no cause or even in gross or reckless disregard of any employee’s rights.” Collins v. Rizkana (1995), 73 Ohio St.3d 65, 67 , 652 N.E.2d 653 .

15
Brunaugh v. Anomatic Corp.green
ohioctapp · 2025 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026However, the at-will- employment doctrine is subject to certain exceptions, including: “(1) the existence of an implied or express contract which alters the terms of discharge; (2) the existence of promissory estoppel where representations or promises were made to an employee; and (3) wrongful discharge in violation of public policy.” Brunaugh v. Anomatic Corp., 2025-Ohio-4833, ¶ 15 (5th Dist.).

11
Deadwyler v. Akron Public Schools, Unpublished Decision (12-31-2003)green
ohioctapp · 2003 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024Summit No. 21549, 2003-Ohio-7173 , ¶ 14 (affirming the trial court’s dismissal of a contract employee’s claim because “[o]nly an employee at will may bring a cause of action under the public policy exception to the at-will employment doctrine.”); State v. Culgan, 9th Dist.

2024Summit No. 21549, 2003-Ohio-7173, ¶ 14 (affirming the trial court’s dismissal of a contract employee’s claim because “[o]nly an employee at will may bring a cause of action under the public policy exception to the at-will employment doctrine.”); State v. Culgan, 9th Dist.

11
Lunsford v. Sterilite of Ohio, L.L.C. (Slip Opinion)green
ohio · 2020 · cited in 1 Ohio opinions naming this issue, 2021–2021
1 sentence

2021Id. at 200 ; see Lunsford v. Sterilite of Ohio, L.L.C., Slip Opinion No. 2020-Ohio-4193, ¶ 26 (noting that “this court has recognized other exceptions to the at-will-employment doctrine, including * * * breach of an implied contract.”).

11
Dean v. Consolidated Equities Realty 3, L.L.C.green
ohioctapp · 2009 · cited in 1 Ohio opinions naming this issue, 2021–2021
2 sentences

2021Equities Realty #3, L.L.C., 182 Ohio App.3d 725 , 2009-Ohio-2480 , 914 N.E.2d 1109, ¶ 12 (1st Dist.) (“the public policy against the alleged conduct of [the defendant] is not manifested clearly enough to warrant abrogating the at-will-employment doctrine”).

2021Equities Realty #3, L.L.C., 182 Ohio App.3d 725 , 2009-Ohio-2480 , 914 N.E.2d 1109, ¶ 12 (1st Dist.) (“the public policy against the alleged conduct of [the defendant] is not manifested clearly enough to warrant abrogating the at-will-employment doctrine”).

11
White v. Simpson Industries, Inc.green
ca6 · 2001 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020White v. Simpson Industries, Inc., 1 Fed.Appx. 462, 468 (6th Cir. 2001); Hall v. ITT Automotive, 362 F.Supp.2d 952, 963 (N.D.

11
Hall v. ITT AUTOMOTIVEgreen
ohnd · 2005 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020White v. Simpson Industries, Inc., 1 Fed.Appx. 462, 468 (6th Cir. 2001); Hall v. ITT Automotive, 362 F.Supp.2d 952, 963 (N.D.

11
Bauer v. Pottsville Area Emergency Medical Services, Inc.green
pasuperct · 2000 · cited in 1 Ohio opinions naming this issue, 2003–2003
1 sentence

2003Serv., Inc. (Pa.Super.2000), 758 A.2d 1265, 1272 (Cavanaugh, J., concurring and dissenting). {¶ 13} The Ohio Supreme Court has expanded an exception to the at-will-employment doctrine when an employee discharge violates a “clear public policy.” *533 Painter v. Graley (1994), 70 Ohio St.3d 377 , 639 N.E.2d 51 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Painter v. Graley green
ohio · 1994
2 sentences

2003Serv., Inc. (Pa.Super.2000), 758 A.2d 1265, 1272 (Cavanaugh, J., concurring and dissenting). {¶ 13} The Ohio Supreme Court has expanded an exception to the at-will-employment doctrine when an employee discharge violates a “clear public policy.” *533 Painter v. Graley (1994), 70 Ohio St.3d 377 , 639 N.E.2d 51 .

2003Serv., Inc. (Pa.Super.2000), 758 A.2d 1265, 1272 (Cavanaugh, J., concurring and dissenting). {¶ 13} The Ohio Supreme Court has expanded an exception to the at-will-employment doctrine when an employee discharge violates a “clear public policy.” *533 Painter v. Graley (1994), 70 Ohio St.3d 377 , 639 N.E.2d 51 .

42001–2003
Mers v. Dispatch Printing Co. green
ohio · 1985
2 sentences

2007Mers v. Dispatch Printing Co. (1985), 19 Ohio St.3d 100 , 483 N.E.2d 150 , paragraph one of the syllabus. {¶ 17} In Greeley v. Miami Valley Maintenance Contr, Inc. (1989), 49 Ohio St.3d 228 , 551 N.E.2d 981 , the Ohio Supreme Court first recognized that there is an exception to the at-will employment doctrine when an employee is discharged or disciplined for a reason that violates the clear public policy of Ohio.

2007Mers v. Dispatch Printing Co. (1985), 19 Ohio St.3d 100 , 483 N.E.2d 150 , paragraph one of the syllabus. {¶ 17} In Greeley v. Miami Valley Maintenance Contr, Inc. (1989), 49 Ohio St.3d 228 , 551 N.E.2d 981 , the Ohio Supreme Court first recognized that there is an exception to the at-will employment doctrine when an employee is discharged or disciplined for a reason that violates the clear public policy of Ohio.

31990–2007
House v. Iacovelli (Slip Opinion) green
ohio · 2020
2 sentences

2026House v. Iacovelli, 2020-Ohio-435, ¶ 11 , citing Greeley v. Miami Valley Maintenance Contrs., 49 Ohio St.3d 228 (1990).

2020Collins, 73 Ohio St.3d at 67-68 , 652 N.E.2d 653 ; House v. Iacovelli, ___ 22 January Term, 2020 Ohio St.3d ___ , 2020-Ohio-435 , ___ N.E.3d ___, ¶ 11, citing Greeley v. Miami Valley Maintenance Contrs., Inc., 49 Ohio St.3d 228, 234 , 551 N.E.2d 981 (1990). {¶ 61} When we defined the common-law tort of invasion of privacy, we declared that Ohio’s clear public policy prohibits the violation of a person’s right to privacy by the wrongful intrusion of private actors.

22020–2026
Phung v. Waste Management, Inc. green
ohio · 1986
2 sentences

1990Phung, supra; Brandenburg, supra. In Mers , however, the Ohio Supreme Court carved two narrow exceptions to the at-will employment doctrine These two exceptions involve the doctrine of promissory estoppel and implied contract which modify original at-will contracts.

1989Phung v. Waste Management, Inc. (1986), 23 Ohio St.3d 100 , 23 OBR 260, 491 N.E.2d 1114 .

21989–1990
Wright v. Honda of America Manufacturing, Inc. green
ohio · 1995
2 sentences

2022Mfg., Inc., 73 Ohio St.3d 571 , 574, 653 N.E.2d 381 (1995) (express or implied contract is one exception to the at-will employment doctrine).

2022Mfg., Inc., 73 Ohio St.3d 571 , 574, 653 N.E.2d 381 (1995) (express or implied contract is one exception to the at-will employment doctrine).

12022–2022
Reasoner v. Bill Woeste Chevrolet, Inc. green
ohioctapp · 1999
1 sentence

2021Id. at 200 ; see Lunsford v. Sterilite of Ohio, L.L.C., Slip Opinion No. 2020-Ohio-4193, ¶ 26 (noting that “this court has recognized other exceptions to the at-will-employment doctrine, including * * * breach of an implied contract.”).

12021–2021
Arnett v. Precision Strip, Inc. neutral
ohioctapp · 2012
1 sentence

2020Thus, “Sutton creates a very limited exception to the at-will employment doctrine for injured employees who suffer retaliation prior to instituting or pursuing a workers’ compensation claim.” Arnett v. Precision Strip, Inc., 2012-Ohio-2693 , 972 N.E.2d 168 , ¶ 19 (3d Dist.), quoting Rose v. CTL Aerospace, Inc., 12th Dist. No. CA2011-09-171, 2012-Ohio-1596 , ¶ 16. -23- {¶48} Courts have used a burden shifting framework in analyzing the causation and overriding-justification elements of a wrongful termination in violation of public policy claim.

12020–2020
Moore v. Animal Fair Pet Center, Inc. green
ohctcomplfrankl · 1995
2 sentences

2010The narrow exception {¶ 22} Therefore we will recognize a very narrow exception to the at-will employment doctrine similar to the one recognized in Moore v. Animal Fair Pet Ctr., Inc. (1995), 81 Ohio Misc.2d 46 , 674 N.E.2d 1269 .

2010The narrow exception {¶ 22} Therefore we will recognize a very narrow exception to the at-will employment doctrine similar to the one recognized in Moore v. Animal Fair Pet Ctr., Inc. (1995), 81 Ohio Misc.2d 46 , 674 N.E.2d 1269 .

12010–2010
Wing v. Anchor Media, Ltd. green
ohio · 1991
1 sentence

2005Wing v. Anchor Media, Ltd. of Texas (1991), 59 Ohio St.3d 108 , 110-111 . {¶ 18} Here, appellees asserted that they had not promised appellant continued employment.

12005–2005
Haynes v. Zoological Society green
ohio · 1995
1 sentence

2003Haynes v. Zoological Soc. of Cincinnati (1995), 73 Ohio St.3d 254 , syllabus.

12003–2003
Wagner v. Allied Steel & Tractor Co. green
ohioctapp · 1995
1 sentence

2000The basic elements of a reverse discrimination case against an employer were set forth in Wagner v. Allied Steel Tractor Co., (1995), 105 Ohio App.3d 611 , 614-615 .

12000–2000
White v. Federal Reserve Bank green
ohioctapp · 1995
1 sentence

2000Bank (1995), 103 Ohio App.3d 534 , 538 , we held "* * * discrimination is much more than public policy in Ohio, it is clearly in and of itself an exception to any at-will employment agreement." White clearly stands for the proposition that a claim for discrimination is an exception to the at-will employment doctrine.

12000–2000
Aranda v. Insurance Co. of North America red
tex · 1988
1 sentence

1991(Tex.1988), 748 S.W.2d 210 , it has also held that there is no exception to the at-will employment doctrine for the implied covenant of good faith and fair dealing.

11991–1991
Lumpkin v. H & C COMMUNICATIONS, INC. green
texapp · 1988
1 sentence

1991Lumpkin v. H & C Communications, Inc. (Tex.App.1988), 755 S.W.2d 538 .

11991–1991
Brandenburger v. Hilti, Inc. green
ohioctapp · 1989
1 sentence

1990Phung, supra; Brandenburg, supra. In Mers , however, the Ohio Supreme Court carved two narrow exceptions to the at-will employment doctrine These two exceptions involve the doctrine of promissory estoppel and implied contract which modify original at-will contracts.

11990–1990

Statutes the citing opinions construe

OH § Ohio Rev. Code § 4113.52 (3) OH § Ohio Rev. Code § 4123.90 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 55 (1985–2025) MO 43 (1985–2021) TX 38 (1987–2025) OH 33 (1989–2026) CA 27 (1991–2021) WA 22 (2001–2026) MI 22 (1993–2025) CT 21 (1980–2023) OK 18 (1987–2025) NY 18 (1982–2025) NC 17 (1998–2025) SC 17 (1994–2019) IL 17 (1981–2025) IA 17 (2000–2025) DC 15 (1989–2013) MA 13 (1992–2014) CO 12 (1991–2026) TN 11 (1996–2025) NV 10 (1984–2009) NE 10 (2001–2025) WV 10 (2000–2023) OR 9 (1989–2015) NM 9 (1993–2016) UT 8 (1991–2015) MS 8 (2005–2026) MN 8 (1987–2014) IN 8 (1986–2020) WY 7 (1997–2024) KS 6 (1998–2019) ID 6 (1996–2015) MD 5 (2001–2026) WI 5 (2000–2020) AR 5 (1997–2026) SD 4 (1993–2024) VA 4 (1993–2008) FL 4 (1989–2009) DE 4 (2002–2025) HI 3 (1996–2002) NJ 3 (1980–2022) ND 3 (1999–2021) AK 2 (1989–2001) LA 2 (2003–2016) AL 2 (1998–2000) GA 2 (2004–2012)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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