employment-at-will doctrine in Pennsylvania

30 Pennsylvania opinions name it 12 courts 1985–2018 0 in the last five years

The cases below were cited by Pennsylvania 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 (18)

Case	Followed	Cited
Paul v. Lankenau Hospitalgreen pa · 1990 · cited in 7 Pennsylvania opinions naming this issue, 1992–2018 2 sentences 2018In Paul v. Lankenau Hospital, [ 569 A.2d 346 (Pa. 1990)], we held that “the doctrine of equitable estoppel is not an exception to the employment at-will doctrine. 2011In Paul v. Lankenau Hospital, 524 Pa. 90, 94 , 569 A.2d 346, 348 (1990), our Supreme Court rejected the theory that detrimental reliance in general could be an exception to the employment at-will doctrine.	4	7
Geary v. United States Steel Corp.green pa · 1974 · cited in 5 Pennsylvania opinions naming this issue, 1985–2009 2 sentences 1990A. The Estoppel Issue We are urged by Appellee and amicus 3 to read our controlling case, Geary v. United States Steel, 456 Pa. 171 , 319 A.2d 174 (1974), as a breakthrough in the recognition of some restrictions on the doctrine of employment at-will. 1990A. The Estoppel Issue We are urged by Appellee and amicus 3 to read our controlling case, Geary v. United States Steel, 456 Pa. 171 , 319 A.2d 174 (1974), as a breakthrough in the recognition of some restrictions on the doctrine of employment at-will.	2	5
Darlington v. General Electricgreen pa · 1986 · cited in 5 Pennsylvania opinions naming this issue, 1986–2005 2 sentences 1993Although in several cases prior to Clay and Paul this Court recognized a cause of action under the specific-intent-to-harm-theory, see Tourville v. Inter-Ocean Insurance Co., 353 Pa.Super. 53 , 508 A.2d 1263 (1986), allocatur denied, 514 Pa. 619 , 521 A.2d 933 (1987); Darlington v. General Electric, 350 Pa.Super. 183 , 504 A.2d 306, 318 (1986), Clay and Paul clearly hold that the only exception to the employment at-will doctrine is where the discharge violates clear mandates of public policy. 1993Although in several cases prior to Clay and Paul this Court recognized a cause of action under the specific-intent-to-harm-theory, see Tourville v. Inter-Ocean Insurance Co., 353 Pa.Super. 53 , 508 A.2d 1263 (1986), allocatur denied, 514 Pa. 619 , 521 A.2d 933 (1987); Darlington v. General Electric, 350 Pa.Super. 183 , 504 A.2d 306, 318 (1986), Clay and Paul clearly hold that the only exception to the employment at-will doctrine is where the discharge violates clear mandates of public policy.	2	5
Toussaint v. Blue Cross & Blue Shieldgreen mich · 1980 · cited in 2 Pennsylvania opinions naming this issue, 1985–1986 2 sentences 1986See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn.1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982). 1986See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn.1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982).	2	2
Veno v. Meredithgreen pa · 1986 · cited in 3 Pennsylvania opinions naming this issue, 1990–2015 2 sentences 2015As the Ciardi court summarized: For example, in Veno v. Meredith, 357 Pa.Super. 85 , 515 A.2d 571 (1986), the state appellate court upheld the trial court’s determination that there was insufficient evidence to overcome the employment at-will presumption where the plaintiff was fired after eight years even though the employee had given up a job with a newspaper and moved his family from New Jersey to Pennsylvania, and had throughout the years refused other employment opportunities); Quint v. Thar Process, Inc., 2011 WL 4345925 , 9 (W.D.Pa. 2015As the Ciardi court summarized: For example, in Veno v. Meredith, 357 Pa.Super. 85 , 515 A.2d 571 (1986), the state appellate court upheld the trial court’s determination that there was insufficient evidence to overcome the employment at-will presumption where the plaintiff was fired after eight years even though the employee had given up a job with a newspaper and moved his family from New Jersey to Pennsylvania, and had throughout the years refused other employment opportunities); Quint v. Thar Process, Inc., 2011 WL 4345925 , 9 (W.D.Pa.	1	3
Ross v. Walkergreen pa · 1891 · cited in 3 Pennsylvania opinions naming this issue, 1985–2002 2 sentences 1995A. The History of the At-Will Doctrine The employment at-will doctrine was established in Pennsylvania by the Pennsylvania Supreme Court in the seminal case of Henry v. Pittsburgh & Lake Erie Railroad Co., 139 Pa. 289 , 21 A. 157 (1891). 1985Smith] 97, 105 (1870), it was said: “When, indeed, a person is employed as an agent, traveller or salesman, for no definite time, the law does not imply a hiring by the year, but at the will of both parties, and the principal has a right to terminate it at any time and to discharge the agent from his service without notice.” See also Henry v. Pittsburgh & Lake Erie Railroad Co., 139 Pa. 289, 297 , 21 A. 157, 158 (1891), where the Court held that an employer "may discharge an employee with or without cause, at pleasure, unless restrained by some contract.” The employment-at-will rule appears to	1	3
Yaindl v. Ingersoll-Rand Co. Standard Pump-Aldrich Divisiongreen pasuperct · 1980 · cited in 3 Pennsylvania opinions naming this issue, 1985–1992 2 sentences 1985One commentator has read this court’s opinion in Yaindl v. Inger-soll-Rand Co., 281 Pa.Super. 560 , 422 A.2d 611 (1980), as in effect abrogating the employment-at-will rule by implying a just cause requirement into employment contracts. 1985One commentator has read this court’s opinion in Yaindl v. Inger-soll-Rand Co., 281 Pa.Super. 560 , 422 A.2d 611 (1980), as in effect abrogating the employment-at-will rule by implying a just cause requirement into employment contracts.	1	3
Shick v. Shireygreen pa · 1998 · cited in 2 Pennsylvania opinions naming this issue, 2002–2015 2 sentences 2015However, we determined in [Shick v. Shirey, 552 Pa. 590, 716- A.2d 1231 (1998),] that an employer who fires an employee in retaliation for bringing a workers’ compensation claim violates the public policy of this Commonwealth and can be liable at common law for wrongful discharge.” Id. at 287 [ 716 A.2d 1231 ]. 2015However, we determined in [Shick v. Shirey, 552 Pa. 590, 716- A.2d 1231 (1998),] that an employer who fires an employee in retaliation for bringing a workers’ compensation claim violates the public policy of this Commonwealth and can be liable at common law for wrongful discharge.” Id. at 287 [ 716 A.2d 1231 ].	1	2
Scott v. Extracorporeal, Inc.green pa · 1988 · cited in 2 Pennsylvania opinions naming this issue, 1992–1993 2 sentences 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros. 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros.	1	2
Clay v. Advanced Computer Applications, Inc.green pa · 1989 · cited in 2 Pennsylvania opinions naming this issue, 1992–1993 2 sentences 1993As the Court expressly reiterated in Lankenau, quoting with approval Clay v. Advance Computer Applications, 522 Pa. 86 , 559 A.2d 917 (1989): "[e]xceptions to [the employment at-will doctrine] have been recognized in only the most limited of circumstances, where discharges of at-will employees would threaten clear mandates of public policy." Lankenau, supra, 524 Pa. at 95 , 569 A.2d at 348 , quoting Clay, supra, 522 Pa. at 89-90, 559 A.2d at 918 . 1993As the Court expressly reiterated in Lankenau, quoting with approval Clay v. Advance Computer Applications, 522 Pa. 86 , 559 A.2d 917 (1989): "[e]xceptions to [the employment at-will doctrine] have been recognized in only the most limited of circumstances, where discharges of at-will employees would threaten clear mandates of public policy." Lankenau, supra, 524 Pa. at 95 , 569 A.2d at 348 , quoting Clay, supra, 522 Pa. at 89-90, 559 A.2d at 918 .	1	2
Roman, B. v. McGuire Memorialgreen pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017 1 sentence 2017An employee will be entitled to bring a cause of action for a termination of that relationship only in the most limited of circumstances where the termination implicates a clear mandate of public policy in this Commonwealth.” Id, Roman v. McGuire Mem’l, 127 A.3d 26, 31-32 (Pa.Super. 2015).	1	1
McLaughlin v. Gastrointestinal Specialists, Inc.green pa · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002 2 sentences 2002“Generally, an employer ‘may discharge an employee with or without cause, at pleasure, unless restrained by some contract.’ Henry v. Pittsburgh & Lake Erie Railroad Company, 189 Pa. 289, 297 , 21 A. 157 (1891).” Shick v. Shirey, 552 Pa. 590, 595 , 716 A.2d 1231, 1233 (1998); accord McLaughlin v. Gastrointestinal Specialists, Inc., 561 Pa. 307 , 750 A.2d 283 (2000) (Pennsylvania courts have recognized for over a century that an employer may terminate an employee for any reason absent contractual provision to the contrary). 2002“Generally, an employer ‘may discharge an employee with or without cause, at pleasure, unless restrained by some contract.’ Henry v. Pittsburgh & Lake Erie Railroad Company, 189 Pa. 289, 297 , 21 A. 157 (1891).” Shick v. Shirey, 552 Pa. 590, 595 , 716 A.2d 1231, 1233 (1998); accord McLaughlin v. Gastrointestinal Specialists, Inc., 561 Pa. 307 , 750 A.2d 283 (2000) (Pennsylvania courts have recognized for over a century that an employer may terminate an employee for any reason absent contractual provision to the contrary).	1	1
Mamlin v. Genoegreen pa · 1940 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002 2 sentences 2002It has observed that while the legislature has the authority to enact public policy as a matter of expediency, when the courts declare public policy, “it must, and may only, be a rebanee upon the consistency with sound policy and good morals as to the consideration or thing to be done.” Shick, supra at 601 , 716 A.2d at 1236 (quoting Mamlin v. Genoe, 340 Pa. 320, 325 , 17 A.2d 407, 409 (1941)). 2002It has observed that while the legislature has the authority to enact public policy as a matter of expediency, when the courts declare public policy, “it must, and may only, be a rebanee upon the consistency with sound policy and good morals as to the consideration or thing to be done.” Shick, supra at 601 , 716 A.2d at 1236 (quoting Mamlin v. Genoe, 340 Pa. 320, 325 , 17 A.2d 407, 409 (1941)).	1	1
Marsh v. Boylegreen pa · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999 2 sentences 1999Appellant argues that the highlighted language supports his claim that the contract provided for employment for a definite term, the run of the tour, and therefore he could only be terminated for just cause. ¶ 8 “Where an employment arrangement does not contain a definite term, it will be presumed that the employment at-will rule applies.” Marsh v. Boyle, 366 Pa.Super. 1 , 530 A.2d 491, 493 (1987) (citation omitted). “ ‘[GJenerally an employment contract for a broad, unspecified duration does not overcome the presumption of at will employment.... 1999Appellant argues that the highlighted language supports his claim that the contract provided for employment for a definite term, the run of the tour, and therefore he could only be terminated for just cause. ¶ 8 “Where an employment arrangement does not contain a definite term, it will be presumed that the employment at-will rule applies.” Marsh v. Boyle, 366 Pa.Super. 1 , 530 A.2d 491, 493 (1987) (citation omitted). “ ‘[GJenerally an employment contract for a broad, unspecified duration does not overcome the presumption of at will employment....	1	1
Murphy v. Publicker Industries, Inc.green pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999 2 sentences 1999Definiteness is required....’” Id., quoting Murphy v. Publisher Industries, Inc., 357 Pa.Super. 409 , 516 A.2d 47, 51-52 (1986) (other citations omitted). 1999Definiteness is required....’” Id., quoting Murphy v. Publisher Industries, Inc., 357 Pa.Super. 409 , 516 A.2d 47, 51-52 (1986) (other citations omitted).	1	1
Mudd v. Hoffman Homes for Youth, Inc.green pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993 2 sentences 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros. 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros.	1	1
Ruzicki v. Catholic Cemeteries Ass'ngreen pasuperct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993 2 sentences 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros. 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros.	1	1
Rutherfoord v. Presbyterian-University Hospitalgreen pasuperct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993 2 sentences 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros. 1993Rutherfoord v. Presbyterian-University Hospital, 417 Pa.Super. 316, 323 , 612 A.2d 500, 503 (1992); Ruzicki v. Catholic Cemeteries Ass'n, 416 Pa.Super. 37, 42 , 610 A.2d 495, 497 (1992); Mudd v. Hoffman Homes for Youth, Inc., 374 Pa.Super. 522, 530 , 543 A.2d 1092, 1096 (1988); Scott v. Extracorporeal, Inc., 376 Pa.Super. 90, 97 , 545 A.2d 334, 338 (1988); Reilly v. Stroehmann Bros.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (13)

Case	Cited	Years
Henry v. Pittsb. Etc. R. green pa · 1891 2 sentences 1995A. The History of the At-Will Doctrine The employment at-will doctrine was established in Pennsylvania by the Pennsylvania Supreme Court in the seminal case of Henry v. Pittsburgh & Lake Erie Railroad Co., 139 Pa. 289 , 21 A. 157 (1891). 1985Smith] 97, 105 (1870), it was said: “When, indeed, a person is employed as an agent, traveller or salesman, for no definite time, the law does not imply a hiring by the year, but at the will of both parties, and the principal has a right to terminate it at any time and to discharge the agent from his service without notice.” See also Henry v. Pittsburgh & Lake Erie Railroad Co., 139 Pa. 289, 297 , 21 A. 157, 158 (1891), where the Court held that an employer "may discharge an employee with or without cause, at pleasure, unless restrained by some contract.” The employment-at-will rule appears to	3	1985–2002
Banas v. Matthews International Corp. green pa · 1985 2 sentences 1986In Banas v. Matthews International Corporation, 348 Pa.Superior Ct. 464, 502 A.2d 637 (1985), this Court had an opportunity to examine the employment-at-will rule. 1986Corp., supra, 348 Pa.Super. at 483-84 , 502 A.2d at 647 , this court wrote: *219 In recent years some courts have held that the employment-at-will rule is inapplicable where the employer has issued an employee handbook containing a provision that commits the employer to dismiss an employee for just cause only, and that an action will lie for breach of such a provision.	2	1986–1986
Pine River State Bank v. Mettille green minn · 1983 2 sentences 1986See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn.1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982). 1985See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn. 1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982).	2	1985–1986
Weiner v. McGraw-Hill, Inc. green ny · 1982 2 sentences 1986See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn.1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982). 1986See, e.g., Toussaint v. Blue Cross & Blue Shield of Michigan, 408 Mich. 579 , 292 N.W.2d 880 (1980); Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn.1983); Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458 , 443 N.E.2d 441 , 457 N.Y.S.2d 193 (1982).	2	1985–1986
Niehaus v. Delaware Valley Medical Center green pasuperct · 1993 2 sentences 2000Paul v. Lankenau Hospital, 524 Pa. 90, 93-95 , 569 A.2d 346, 348 (1990). ¶ 7 Several years later, in Niehaus v. Delaware Valley Medical Center, 429 Pa.Super. 119 , 631 A.2d 1314 (1993), this court ruled in a divided three-member panel decision that an employee could sue a former employer for breach of contract where an employee handbook provided for rehire under the circumstances present. 2000Paul v. Lankenau Hospital, 524 Pa. 90, 93-95 , 569 A.2d 346, 348 (1990). ¶ 7 Several years later, in Niehaus v. Delaware Valley Medical Center, 429 Pa.Super. 119 , 631 A.2d 1314 (1993), this court ruled in a divided three-member panel decision that an employee could sue a former employer for breach of contract where an employee handbook provided for rehire under the circumstances present.	1	2000–2000
Lochner v. New York red scotus · 1905 2 sentences 1999Employment at Will supra, at 128-29. [14] The paradigmatic case representing the now discredited era of substantive due process was Lochner v. New York, 198 U.S. 45 , 25 S.Ct. 539 , 49 L.Ed. 937 (1905), which struck down a state law prohibiting bakers from working more than 10 hours a day on the basis of the inviolability of "freedom of contract." However, well before Lochner , the Pennsylvania Supreme Court decided the first case in the nation affecting factory wage labor, invalidating, again on the basis of "liberty of contract," a Pennsylvania statute that required that all laborers "in and 1999Employment at Will supra, at 128-29. [14] The paradigmatic case representing the now discredited era of substantive due process was Lochner v. New York, 198 U.S. 45 , 25 S.Ct. 539 , 49 L.Ed. 937 (1905), which struck down a state law prohibiting bakers from working more than 10 hours a day on the basis of the inviolability of "freedom of contract." However, well before Lochner , the Pennsylvania Supreme Court decided the first case in the nation affecting factory wage labor, invalidating, again on the basis of "liberty of contract," a Pennsylvania statute that required that all laborers "in and	1	1999–1999
Cisco v. United Parcel Services, Inc. green pa · 1984 2 sentences 1999Justices Nix and Manderino also dissented. [20] In Cisco v. United Parcel Services, Inc., 328 Pa.Super. 300 , 476 A.2d 1340 (1984), this Court stated: "The sources of public policy [which may limit the employer's right of discharge] include legislation; administrative rules, regulation, or decision; and judicial decision. 1999Justices Nix and Manderino also dissented. [20] In Cisco v. United Parcel Services, Inc., 328 Pa.Super. 300 , 476 A.2d 1340 (1984), this Court stated: "The sources of public policy [which may limit the employer's right of discharge] include legislation; administrative rules, regulation, or decision; and judicial decision.	1	1999–1999
Williams v. Philadelphia Housing Authority green paed · 1993 2 sentences 1994An 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. 1994An 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.	1	1994–1994
Tourville v. Inter-Ocean Insurance green pa · 1986 2 sentences 1993Although in several cases prior to Clay and Paul this Court recognized a cause of action under the specific-intent-to-harm-theory, see Tourville v. Inter-Ocean Insurance Co., 353 Pa.Super. 53 , 508 A.2d 1263 (1986), allocatur denied, 514 Pa. 619 , 521 A.2d 933 (1987); Darlington v. General Electric, 350 Pa.Super. 183 , 504 A.2d 306, 318 (1986), Clay and Paul clearly hold that the only exception to the employment at-will doctrine is where the discharge violates clear mandates of public policy. 1993Although in several cases prior to Clay and Paul this Court recognized a cause of action under the specific-intent-to-harm-theory, see Tourville v. Inter-Ocean Insurance Co., 353 Pa.Super. 53 , 508 A.2d 1263 (1986), allocatur denied, 514 Pa. 619 , 521 A.2d 933 (1987); Darlington v. General Electric, 350 Pa.Super. 183 , 504 A.2d 306, 318 (1986), Clay and Paul clearly hold that the only exception to the employment at-will doctrine is where the discharge violates clear mandates of public policy.	1	1993–1993
Yetterant v. Ward Trucking Corp. green pasuperct · 1991 2 sentences 1991Thus, to survive a challenge of failure to state a cause of action, the complaint must establish the violation of a public policy.” Yetter v. Ward Trucking Corporation, 401 Pa. Super. 467 , 585 A.2d 1022 (1991). 1991Thus, to survive a challenge of failure to state a cause of action, the complaint must establish the violation of a public policy.” Yetter v. Ward Trucking Corporation, 401 Pa. Super. 467 , 585 A.2d 1022 (1991).	1	1991–1991
Petermann v. International Brotherhood of Teamsters, Local 396 green calctapp · 1959 1 sentence 1989Erosion of the at-will doctrine began in 1959 when the California courts opened the door to an action for wrongful discharge in Peterman v. International Brotherhood of Teamsters, 174 Cal. App. 2d 184 (1959).	1	1989–1989
Martin v. Tapley green ala · 1978 1 sentence 1987Martin v. Tapley, 360 So.2d 708 (Ala. 1978).	1	1987–1987
Cummings v. Kelling Nut Co. green pa · 1951	1	1986–1986

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 505 (3) PA § 18 Pa. Cons. Stat. § 7321 (3) PA § 42 Pa. Cons. Stat. § 4563 (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

OH 249 (1984–2026) TX 138 (1986–2025) VA 47 (1987–2025) TN 45 (1994–2025) IN 37 (1986–2025) MO 37 (1985–2020) KS 36 (1985–2023) NC 33 (1987–2022) PA 30 (1985–2018) CT 28 (1992–2021) OK 27 (1989–2022) AR 26 (1984–2026) IA 23 (1989–2024) MS 22 (1992–2023) AL 21 (1984–2003) WI 21 (1982–2023) WA 19 (1986–2011) NY 18 (1989–2018) NJ 16 (1979–2021) IL 14 (1986–2008) SC 14 (1995–2016) DC 12 (1993–2018) MN 11 (1987–2017) SD 10 (1988–2024) UT 9 (1989–2007) LA 8 (1989–2020) ND 8 (1998–2021) DE 7 (2000–2026) CA 7 (1983–2000) VT 7 (1994–2023) MI 7 (1984–1995) KY 6 (1983–2021) ID 5 (1990–2009) NE 5 (1987–2025) AZ 4 (1980–1990) MA 4 (1993–2016) MD 4 (2003–2015) FL 3 (1986–2004) WY 3 (1990–2009)

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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