11 Minnesota opinions name it 2 courts 1987–2017 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.
| Case | Followed | Cited |
|---|---|---|
Phipps v. Clark Oil & Refining Corp.green2 sentences2017We have recognized a narrow common-law public-policy exception to the employment-at-will doctrine, allowing an employee to bring an action for wrongful discharge at common law only where “a termination is the result of an employee’s refusal to do an act that the employee, in good faith, believes to be illegal.” Dukowitz, 841 N.W.2d at 151 ; Phipps v. Clark Oil & Ref Corp., 408 N.W.2d 569, 571 (Minn. 1987). 2014Corp., 408 N.W.2d 569, 571 (Minn.1987) (recognizing public-policy exception to the employment-at-will rule). | 3 | 5 |
Anderson-Johanningmeier v. Mid-Minnesota Women's Center, Inc.green2 sentences2009Anderson-Johanningmeier v. Mid-Minnesota Women's Ctr., Inc., 637 N.W.2d 270, 273 (Minn.2002); see also 17 Stephen F. Befort, Minnesota Practice-Employment Law & Practice § 11.1 (2d ed. 2003) (discussing the employment-at-will doctrine). 2009Anderson-Johanningmeier v. Mid-Minnesota Women's Ctr., Inc., 637 N.W.2d 270, 273 (Minn.2002); see also 17 Stephen F. Befort, Minnesota Practice-Employment Law & Practice § 11.1 (2d ed. 2003) (discussing the employment-at-will doctrine). | 2 | 2 |
Pine River State Bank v. Mettillegreen2 sentences2002Pine River State Bank v. Mettille, 333 N.W.2d 622, 627 (Minn.1983). 2002Pine River State Bank v. Mettille, 333 N.W.2d 622, 627 (Minn.1983). | 2 | 2 |
Dukowitz v. Hannon Security Servicesgreen2 sentences2017We have recognized a narrow common-law public-policy exception to the employment-at-will doctrine, allowing an employee to bring an action for wrongful discharge at common law only where “a termination is the result of an employee’s refusal to do an act that the employee, in good faith, believes to be illegal.” Dukowitz, 841 N.W.2d at 151 ; Phipps v. Clark Oil & Ref Corp., 408 N.W.2d 569, 571 (Minn. 1987). 2017We “decline[d] to expand the public-policy exception to the employment-at-will rule,” explaining that “the Legislature has already delineated the consequences” for a statutory violation, including “an extensive scheme of administrative and criminal penalties.” Id. at 15S. 1 Contrary to Dukowitz, the majority usurps the policymaking role of the Legislature by rewriting Minn. Stat. § 177.24 to prohibit an employer from terminating an employee for refusing to share tips. | 1 | 3 |
Nelson v. Productive Alternatives, Inc.green2 sentences2017The majority points to the polygraph statute, Minn. Stat. § 181.75 (2016), as ah example of a statutory exception to the employment-at-will rule, citing our decision in Nelson v. Productive Alternatives, Inc., 715 N.W.2d 452 (Minn. 2006). 2014We have not yet applied the public-policy exception to the employment-at-will rule beyond the circumstances that were present in Phipps . 1 See Nelson v. Productive Alts., Inc., 715 N.W.2d 452 , 457 n. 5 (Minn.2006) (declining to consider whether “other discharges in violation of public policy give rise to common-law causes of action, aside from those that we already recognized in Phipps ”). | 1 | 3 |
Sabetay v. Sterling Drug, Inc.green2 sentences2014See Sabetay v. Sterling Drug, Inc., 69 N.Y.2d 329 , 514 N.Y.S.2d 209 , 506 N.E.2d 919, 920 (1987) (“The original purposes of the employment at-will doctrine were to afford employees the freedom to contract to suit their needs and to allow employers to exercise their best judgment with regard to employment matters.”). 2014See Sabetay v. Sterling Drug, Inc., 69 N.Y.2d 329 , 514 N.Y.S.2d 209 , 506 N.E.2d 919, 920 (1987) (“The original purposes of the employment at-will doctrine were to afford employees the freedom to contract to suit their needs and to allow employers to exercise their best judgment with regard to employment matters.”). | 1 | 1 |
Abraham v. County of Hennepingreen1 sentence2014See Abraham v. Cnty. of Hennepin, 639 N.W.2d 342, 351-52 (Minn.2002). | 1 | 1 |
Darnell v. Impact Industries, Inc.green2 sentences2014See, e.g., Darnell v. Impact Indus., Inc., 105 Ill.2d 158 , 85 Ill.Dec. 336 , 473 N.E.2d 935, 937 (1984); Frampton v. Cent. 2014See, e.g., Darnell v. Impact Indus., Inc., 105 Ill.2d 158 , 85 Ill.Dec. 336 , 473 N.E.2d 935, 937 (1984); Frampton v. Cent. | 1 | 1 |
Cederstrand v. Lutheran Brotherhoodgreen2 sentences2002Traditionally, an "employer-employee relationship is terminable at the will of either; the employer can summarily dismiss the employee, the employee is under no obligation to remain at the job." Cederstrand v. Lutheran Bhd., 263 Minn. 520, 532 , 117 N.W.2d 213, 221 (1962). 2002Traditionally, an "employer-employee relationship is terminable at the will of either; the employer can summarily dismiss the employee, the employee is under no obligation to remain at the job." Cederstrand v. Lutheran Bhd., 263 Minn. 520, 532 , 117 N.W.2d 213, 221 (1962). | 1 | 1 |
Lewis v. Equitable Life Assurance Society of the United Statesgreen1 sentence1987See Lewis, 389 N.W.2d at 893 (Kelley, J., dissenting). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Dukowitz v. Hannon Security Services
green
1 sentence2014Id. at 851 . | 1 | 2014–2014 |
Huyen v. Driscoll
green
2 sentences2011In light of the employment-at-will doctrine, an employer’s constructive discharge of an employee has the same legal consequences as any other discharge of an employee, which is to say that it has no consequences with respect to liability, unless the discharge was motivated by an unlawful reason. 4 Accordingly, in Huyen v. Driscoll, 479 N.W.2d 76 (Minn.App.1991), review denied (Minn. Feb. 10, 1992), we stated that constructive dis charge is a “companion tort” and that, for the doctrine to be efficacious, the plaintiff also “must establish the underlying illegality.” Id. at 81 . 2011In light of the employment-at-will doctrine, an employer’s constructive discharge of an employee has the same legal consequences as any other discharge of an employee, which is to say that it has no consequences with respect to liability, unless the discharge was motivated by an unlawful reason. 4 Accordingly, in Huyen v. Driscoll, 479 N.W.2d 76 (Minn.App.1991), review denied (Minn. Feb. 10, 1992), we stated that constructive dis charge is a “companion tort” and that, for the doctrine to be efficacious, the plaintiff also “must establish the underlying illegality.” Id. at 81 . | 1 | 2011–2011 |
Pribil v. Archdiocese of St. Paul & Minneapolis
green
1 sentence2011Similarly, we stated in Pribil that constructive discharge must be accompanied by proof of intentional wrongdoing by the employer against the employee. 533 N.W.2d at 413 . | 1 | 2011–2011 |
Hunt v. IBM Mid America Employees Federal Credit Union
green
1 sentence1987Although the Minnesota Supreme Court has declined to imply a covenant of good faith and fair dealing into every employment contract, Hunt v. IBM Mid America Employees Federal Credit Union, 384 N.W.2d 853 (Minn.1986), it has followed the modern trend in recognizing exceptions to employment at will. | 1 | 1987–1987 |
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.
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.