at-will presumption (Wyoming) · Go Syfert
← Wyoming issues

at-will presumption in Wyoming

12 Wyoming opinions name it 1 courts 1989–2010 0 in the last five years

The cases below were cited by Wyoming 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 (12)

CaseFollowedCited
Brodie v. General Chemical Corp.green
wyo · 1997 · cited in 3 Wyoming opinions naming this issue, 1999–2000
2 sentences

2000Brodie v. General Chemical Corporation, 934 P.2d 1263, 1265 (Wyo.1997); Davis, 934 P.2d at 1249 .

1999Brodie v. General Chemical Corporation, 934 P.2d 1263, 1265 (Wyo.1997); Davis, 934 P.2d at 1249 .

33
Wilder v. Cody Country Chamber of Commercegreen
wyo · 1994 · cited in 3 Wyoming opinions naming this issue, 1997–2000
2 sentences

2000Wilder, 868 P.2d at 218 (holding that employer promise of "permanent" employment does not alter the at-will presumption without additional consideration supplied by the employee or explicit language in the contract of employment stating that termination may only be for cause); Bear v. Volunteers of America, Wyoming, Inc., 964 P.2d at 1250.

2000Wilder, 868 P.2d at 218 (holding that employer promise of "permanent" employment does not alter the at-will presumption without additional consideration supplied by the employee or explicit language in the contract of employment stating that termination may only be for cause); Bear v. Volunteers of America, Wyoming, Inc., 964 P.2d at 1250.

23
McDonald v. Mobil Coal Producing, Inc.green
wyo · 1991 · cited in 2 Wyoming opinions naming this issue, 1997–1998
2 sentences

1998Id.; McDonald v. Mobil Coal Producing, Inc., 820 P.2d 986, 990 (Wyo.1991).

1997McDonald v. Mobil Coal Producing, Inc., 820 P.2d 986, 990 (Wyo.1991).

22
Scherer Construction, LLC v. Hedquist Construction, Inc.green
wyo · 2001 · cited in 1 Wyoming opinions naming this issue, 2010–2010
2 sentences

2010Reynolds does not cite any case law in support of this theory, and we have held that "[tlhe existence of a contractual implied covenant [of good faith and fair dealing] is obviously incompatible with the at-will presumption and is not applicable in those situations." Scherer Constr., LLC v. Hedquist Constr., Inc., 2001 WY 23, ¶23 , 18 P.3d 645, 655 (Wyo.2001).

2010Reynolds does not cite any case law in support of this theory, and we have held that "[tlhe existence of a contractual implied covenant [of good faith and fair dealing] is obviously incompatible with the at-will presumption and is not applicable in those situations." Scherer Constr., LLC v. Hedquist Constr., Inc., 2001 WY 23, ¶23 , 18 P.3d 645, 655 (Wyo.2001).

11
Loghry v. Unicover Corp.green
wyo · 1996 · cited in 1 Wyoming opinions naming this issue, 1997–1997
1 sentence

1997Loghry , at 710-11.

11
Lincoln v. Wackenhut Corp.green
wyo · 1994 · cited in 1 Wyoming opinions naming this issue, 1997–1997
1 sentence

1997Wilder v. Cody Country Chamber of Commerce, 868 P.2d 211, 217 (Wyo.1994); Lincoln v. Wackenhut Corp., 867 P.2d 701, 708 (Wyo.1994).

11
Garcia v. UniWyo Federal Credit Uniongreen
wyo · 1996 · cited in 1 Wyoming opinions naming this issue, 1996–1996
1 sentence

1996Garcia v. UniWyo Federal Credit Union, 920 P.2d 642, 647 (Wyo.1996).

11
Capriulo v. Bankers Life Co.green
gactapp · 1986 · cited in 1 Wyoming opinions naming this issue, 1992–1992
2 sentences

1992Capriulo v. Bankers Life Co., 178 Ga.App. 635 , 344 S.E.2d 430, 434 (1986).

1992Capriulo v. Bankers Life Co., 178 Ga.App. 635 , 344 S.E.2d 430, 434 (1986).

11
Allen v. Safeway Stores, Inc.green
wyo · 1985 · cited in 1 Wyoming opinions naming this issue, 1990–1990
2 sentences

1990Although I concur in most aspects of the majority opinion, I dissent from that part of it that holds that “the public policy exception to the employment-at-will doctrine [does] not apply to the termination of employment contracts between school districts and initial contract teachers.” This court identified the rationale supporting the public policy exception to the at-will rule in Allen v. Safeway Stores, Incorporated, 699 P.2d 277, 284 (Wyo.1985): A tort action premised on violation of public policy results from a recognition that allowing a discharge to go unre-dressed would leave a valuabl

1990Although I concur in most aspects of the majority opinion, I dissent from that part of it that holds that "the public policy exception to the employment-at-will doctrine [does] not apply to the termination of employment contracts between school districts and initial contract teachers." This court identified the rationale supporting the public policy exception to the at-will rule in Allen v. Safeway Stores, Incorporated, 699 P.2d 277, 284 (Wyo. 1985): A tort action premised on violation of public policy results from a recognition that allowing a discharge to go unredressed would leave a valuabl

11
Wagner v. City of Globegreen
ariz · 1986 · cited in 1 Wyoming opinions naming this issue, 1990–1990
2 sentences

1990As it was so aptly put by the Arizona Supreme Court in Wagner v. City of Globe, 150 Ariz. 82 , 722 P.2d 250, 255-56 (1986), [e]mployees should not have to choose between their jobs and the demands of important public policy interests * * *. [E]mployees should not be discharged because they performed an act that public policy would encourage * * *.

1990As it was so aptly put by the Arizona Supreme Court in Wagner v. City of Globe, 150 Ariz. 82 , 722 P.2d 250, 255-56 (1986), [e]mployees should not have to choose between their jobs and the demands of important public policy interests * * *. [E]mployees should not be discharged because they performed an act that public policy would encourage * * *.

11
Kouff v. Bethlehem-Alameda Shipyard, Inc.green
calctapp · 1949 · cited in 1 Wyoming opinions naming this issue, 1989–1989
2 sentences

1989See Kouff v. Bethlehem-Alameda Shipyard, 90 Cal.App.2d 322 , 202 P.2d 1059 (1949) (statute prohibiting discharge for serving as an election officer).

1989See Kouff v. Bethlehem-Alameda Shipyard, 90 Cal.App.2d 322 , 202 P.2d 1059 (1949) (statute prohibiting discharge for serving as an election officer).

11
Wagenseller v. Scottsdale Memorial Hospitalgreen
ariz · 1985 · cited in 1 Wyoming opinions naming this issue, 1989–1989
2 sentences

1989This doctrine was explained in Wagenseller v. Scottsdale Memorial Hospital, 147 Ariz. 370 , 710 P.2d 1025, 1031-32 (1985) (footnotes omitted): *76 The public policy exception to the at-will doctrine began with a narrow rule permitting employees to sue their employers when a statute expressly prohibited their discharge.

1989This doctrine was explained in Wagenseller v. Scottsdale Memorial Hospital, 147 Ariz. 370 , 710 P.2d 1025, 1031-32 (1985) (footnotes omitted): *76 The public policy exception to the at-will doctrine began with a narrow rule permitting employees to sue their employers when a statute expressly prohibited their discharge.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Davis v. Wyoming Medical Center, Inc. green
wyo · 1997
2 sentences

2000Brodie v. General Chemical Corporation, 934 P.2d 1263, 1265 (Wyo.1997); Davis, 934 P.2d at 1249 .

1999Brodie v. General Chemical Corporation, 934 P.2d 1263, 1265 (Wyo.1997); Davis, 934 P.2d at 1249 .

21999–2000

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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