at-will doctrine (Minnesota) · Go Syfert
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at-will doctrine in Minnesota

14 Minnesota opinions name it 2 courts 1983–2017 0 in the last five years

The cases below were cited by Minnesota 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 (14)

CaseFollowedCited
Pine River State Bank v. Mettillegreen
minn · 1983 · cited in 7 Minnesota opinions naming this issue, 1986–2017
2 sentences

2017In relation to employment contracts, the Minnesota Supreme Court explained in Pine River State Bank v. Mettille that the rule of at-will employment is a rule of construction and that “cases which reason that the at-will rule takes precedence over even explicit job termination restraints, simply because the contract is of indefinite duration, misapply the at-will rule of construction as a rule of substantive limitation on contract formation.” 333 N.W.2d 622, 628 (Minn. 1983).

2016Under the at-will doctrine, “an employer may discharge an employee for ‘any reason or no reason’ and ,. ah employee is ‘under no obligation to remain on the job.’ ” Id. (quoting Pine River State Bank v. Mettille, 333 N.W.2d 622, 627 (Minn.1983)).

57
Grouse v. Group Health Plan, Inc.green
minn · 1981 · cited in 3 Minnesota opinions naming this issue, 1988–1989
2 sentences

1989See Grouse v. Group Health Plan, Inc., 306 N.W.2d 114 (Minn.1981) (employer revoked job offer despite employee’s resignation from prior job and rejection of other job offer).

1989See Grouse v. Group Health Plan, Inc., 306 N.W.2d 114, 116 (Minn.1981).

33
Dukowitz v. Hannon Security Servicesgreen
minn · 2014 · cited in 2 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016Under the at-will doctrine, “an employer may discharge an employee for ‘any reason or no reason’ and . . . an employee is ‘under no obligation to remain on the job.’” Id. (quoting Pine River State Bank v. Mettille, 333 N.W.2d 622, 627 (Minn. 1983)).

2016Under the at-will doctrine, “an employer may discharge an employee for ‘any reason or no reason’ and ,. ah employee is ‘under no obligation to remain on the job.’ ” Id. (quoting Pine River State Bank v. Mettille, 333 N.W.2d 622, 627 (Minn.1983)).

12
Berube v. Fashion Centre, Ltd.green
utah · 1989 · cited in 1 Minnesota opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 684 (1992) (“[T]he [public] policy must be fundamental, substantial and well established at the time of the discharge.” (quotations omitted)), abrogated on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1043 (Utah 1989) (holding that the court would recognize only those public policies that “are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub

11
Green v. Ralee Engineering Co.green
cal · 1998 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 684 (1992) (“[T]he [public] policy must be fundamental, substantial and well established at the time of the discharge.” (quotations omitted)), abrogated on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1043 (Utah 1989) (holding that the court would recognize only those public policies that “are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub

2006See, e.g., Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 684 (1992) (“[T]he [public] policy must be fundamental, substantial and well established at the time of the discharge.” (quotations omitted)), abrogated on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1043 (Utah 1989) (holding that the court would recognize only those public policies that “are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub

11
Gantt v. Sentry Insurancegreen
cal · 1992 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 684 (1992) (“[T]he [public] policy must be fundamental, substantial and well established at the time of the discharge.” (quotations omitted)), abrogated on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1043 (Utah 1989) (holding that the court would recognize only those public policies that “are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub

2006See, e.g., Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 684 (1992) (“[T]he [public] policy must be fundamental, substantial and well established at the time of the discharge.” (quotations omitted)), abrogated on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1043 (Utah 1989) (holding that the court would recognize only those public policies that “are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub

11
Phipps v. Clark Oil & Refining Corp.green
minnctapp · 1987 · cited in 1 Minnesota opinions naming this issue, 2006–2006
1 sentence

2006Corp., 396 N.W.2d 588, 592 (Minn.App.1986), affd, 408 N.W.2d 569 (Minn.1987).

11
Rosenberg v. Heritage Renovations, LLCgreen
minn · 2004 · cited in 1 Minnesota opinions naming this issue, 2005–2005
1 sentence

2005See Rosenberg, 685 N.W.2d at 326 (holding that employment was at will despite a reference to events in the employment listing that could be used- as a termination date); Harris, 421 N.W.2d at 354 . (holding that a buy-back agreement for company stock in the event of termination did not modify at-will employment status).

11
Skagerberg v. Blandin Paper Co.green
minn · 1936 · cited in 1 Minnesota opinions naming this issue, 2001–2001
1 sentence

2001See Degen, 260 Minn. at *183 429-30, 110 N.W.2d at 867 (concluding that acceptance of salary reduction, forbearance of employment, and contributions to pension plan were insufficient to constitute additional consideration); Skagerberg , 197 Minn, at 300-03, 266 N.W. at 876-78 (concluding that forbearance of a lucrative consulting practice to accept new position did not constitute sufficient additional consideration to create implied contract limiting discharge to good cause); Dumas, 380 N.W.2d at 546 (stating that consideration for a promise of permanent employment must be regarded by the part

11
Dumas v. Kessler & Maguire Funeral Home, Inc.green
minnctapp · 1986 · cited in 1 Minnesota opinions naming this issue, 2001–2001
1 sentence

2001See Degen, 260 Minn. at *183 429-30, 110 N.W.2d at 867 (concluding that acceptance of salary reduction, forbearance of employment, and contributions to pension plan were insufficient to constitute additional consideration); Skagerberg , 197 Minn, at 300-03, 266 N.W. at 876-78 (concluding that forbearance of a lucrative consulting practice to accept new position did not constitute sufficient additional consideration to create implied contract limiting discharge to good cause); Dumas, 380 N.W.2d at 546 (stating that consideration for a promise of permanent employment must be regarded by the part

11
Degen v. Investors Diversified Services, Inc.green
minn · 1961 · cited in 1 Minnesota opinions naming this issue, 2001–2001
1 sentence

2001See Degen, 260 Minn. at *183 429-30, 110 N.W.2d at 867 (concluding that acceptance of salary reduction, forbearance of employment, and contributions to pension plan were insufficient to constitute additional consideration); Skagerberg , 197 Minn, at 300-03, 266 N.W. at 876-78 (concluding that forbearance of a lucrative consulting practice to accept new position did not constitute sufficient additional consideration to create implied contract limiting discharge to good cause); Dumas, 380 N.W.2d at 546 (stating that consideration for a promise of permanent employment must be regarded by the part

11
Littell v. Evening Star Newspaper Co.green
cadc · 1941 · cited in 1 Minnesota opinions naming this issue, 1983–1983
1 sentence

1983See Littell v. Evening Star Newspaper Co., 120 F.2d 36, 37 (D.C.Cir.1941); Drzewiecki v. H & R Block, Inc., 24 Cal.App.3d 695, 703-04 , 101 Cal.Rptr. 169, 174 (1972).

11
Drzewiecki v. H & R BLOCK, INC.green
calctapp · 1972 · cited in 1 Minnesota opinions naming this issue, 1983–1983
2 sentences

1983See Littell v. Evening Star Newspaper Co., 120 F.2d 36, 37 (D.C.Cir.1941); Drzewiecki v. H & R Block, Inc., 24 Cal.App.3d 695, 703-04 , 101 Cal.Rptr. 169, 174 (1972).

1983See Littell v. Evening Star Newspaper Co., 120 F.2d 36, 37 (D.C.Cir.1941); Drzewiecki v. H & R Block, Inc., 24 Cal.App.3d 695, 703-04 , 101 Cal.Rptr. 169, 174 (1972).

11
Johnson v. National Beef Packing Co.green
kan · 1976 · cited in 1 Minnesota opinions naming this issue, 1983–1983
2 sentences

1983See, e.g., Johnson v. National Beef Packing Co., 220 Kan. 52 , 551 P.2d 779 (1976); Shaw v. S.S.

1983See, e.g., Johnson v. National Beef Packing Co., 220 Kan. 52 , 551 P.2d 779 (1976); Shaw v. S.S.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Pedro v. Pedrogreen
minnctapp · 1990 · cited in 1 Minnesota opinions naming this issue, 2001–2001
1 sentence

2001But see Pedro I, 463 N.W.2d at 289-90 (suggesting that a close-corporation shareholder’s reasonable expectation of employment with the corporation, rather than a contractual agreement, is an appropriate basis for a wrongful-termination claim despite the at-will doctrine); Schlafge, supra, at 1089-96 (concluding that the Pedro I court “extended the law too far in its efforts to compensate a sympathetic plaintiff’).

11

Also cited on this issue (4)

CaseCitedYears
Nelson v. Productive Alternatives, Inc. green
minn · 2006
2 sentences

2016Our conclusion is reinforced by the Minnesota Supreme Court’s decision in Nelson v. Productive Alternatives, Inc., 715 N.W.2d 452 (Minn.2006), considering whether the Minnesota Whistleblower Act abrogated the public-policy exception to the at-will doctrine.

2016The supreme court in Nelson introduced the at-will doctrine and noted that “there are several statutory exceptions to the at-will rule.” Id. at 454 .

42012–2017
Phipps v. Clark Oil & Refining Corp. green
minn · 1987
2 sentences

2006Though there are several statutory exceptions to the at-will rule, 1 we have only recognized a common-law cause of action for wrongful discharge in violation of public policy once, in Phipps v. Clark Oil & Refining Corp., 408 N.W.2d 569 .

2006Corp., 396 N.W.2d 588, 592 (Minn.App.1986), affd, 408 N.W.2d 569 (Minn.1987).

21989–2006
Harris v. Mardan Business Systems, Inc. green
minnctapp · 1988
1 sentence

2005See Rosenberg, 685 N.W.2d at 326 (holding that employment was at will despite a reference to events in the employment listing that could be used- as a termination date); Harris, 421 N.W.2d at 354 . (holding that a buy-back agreement for company stock in the event of termination did not modify at-will employment status).

12005–2005
Hunt v. IBM Mid America Employees Federal Credit Union green
minn · 1986
1 sentence

1988Hunt, 384 N.W.2d at 856 n. 7.

11988–1988

Statutes the citing opinions construe

MN § Minn. Stat. § 176.82 (4) MN § Minn. Stat. § 181.75 (4) MN § Minn. Stat. § 144.4196 (3) MN § Minn. Stat. § 177.21 (3) MN § Minn. Stat. § 177.24 (3) MN § Minn. Stat. § 177.27 (3) MN § Minn. Stat. § 645.16 (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 69 (1985–2025) TX 43 (1986–2025) DC 26 (1991–2018) UT 22 (1989–2018) CA 22 (1988–2021) WA 21 (1989–2023) AR 20 (1983–2021) OH 19 (1986–2022) NY 17 (1983–2018) OK 17 (1987–2022) ND 16 (1987–2021) MN 14 (1983–2017) AZ 13 (1984–2001) NC 12 (1989–2011) NM 12 (1986–2005) IA 12 (1989–2024) WY 12 (1989–2010) MO 12 (1985–2020) CT 11 (1985–2016) MS 11 (1999–2023) MA 10 (1987–2025) VA 10 (1992–2016) WI 10 (1984–2023) NJ 8 (1985–2002) ID 7 (1988–2015) IN 7 (1997–2019) VT 7 (1985–2015) AL 7 (1987–2008) NV 7 (1984–2022) SD 7 (1988–2024) KY 7 (1998–2022) MD 6 (1995–2015) TN 6 (1997–2011) HI 5 (1982–2008) IL 5 (1990–2025) MI 4 (2009–2022) SC 4 (1984–2013) WV 4 (1996–2022) OR 4 (1989–2006) NE 3 (1983–1988) DE 3 (1996–2022) NH 3 (1988–2015) FL 2 (1989–1993) GA 2 (2004–2018)

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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