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

7 Indiana opinions name it 2 courts 1997–2019 0 in the last five years

The cases below were cited by Indiana 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 (8)

CaseFollowedCited
Mead Johnson and Co. v. Oppenheimergreen
indctapp · 1984 · cited in 2 Indiana opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App. 1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App. 1980) (no discussion of the terms of the handbook); Shaw v. S.S.

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App.1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App.1980) (no discussion of the terms of the handbook); Shaw v. S.S.

22
Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklingreen
indctapp · 1986 · cited in 2 Indiana opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App. 1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App. 1980) (no discussion of the terms of the handbook); Shaw v. S.S.

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App.1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App.1980) (no discussion of the terms of the handbook); Shaw v. S.S.

22
Shaw v. SS Kresge Companygreen
indctapp · 1975 · cited in 2 Indiana opinions naming this issue, 1997–1997
2 sentences

1997Kresge Co., 167 Ind.App. 1, 6-7 , 328 N.E.2d 775, 778-79 (1975) (discussing terms of the handbook, which were general, and stating that, as the contract was not a term contract, the court does not reach the question whether a unilateral contract might result from an employer’s promise supported by the consideration provided by an employee’s services or reliance on the promise). .

1997Kresge Co., 167 Ind.App. 1, 6-7 , 328 N.E.2d 775, 778-79 (1975) (discussing terms of the handbook, which were general, and stating that, as the contract was not a term contract, the court does not reach the question whether a unilateral contract might result from an employer’s promise supported by the consideration provided by an employee’s services or reliance on the promise). .

22
Campbell v. Eli Lilly & Co.green
indctapp · 1980 · cited in 2 Indiana opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App. 1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App. 1980) (no discussion of the terms of the handbook); Shaw v. S.S.

1997See, e.g., Tri-City Comprehensive Community Mental Health Center, Inc. v. Franklin, 498 N.E.2d 1303, 1305-06 (Ind.Ct.App.1986) (no discussion of the terms of the policy manual in the majority opinion); Mead Johnson and Co. v. Oppenheimer, 458 N.E.2d 668, 671 (Ind.Ct.App.1984) (no discussion of the terms of the handbook; states that, under the at-will rule, certain contractual limitations may arise, but not on the facts of the case before it); Campbell v. Eli Lilly and Co., 413 N.E.2d 1054, 1062 (Ind.Ct.App.1980) (no discussion of the terms of the handbook); Shaw v. S.S.

22
Kimberlin v. DeLonggreen
ind · 1994 · cited in 2 Indiana opinions naming this issue, 1997–1997
2 sentences

1997See Kimberlin v. DeLong, 637 N.E.2d 121 , 123 n. 1 (Ind.1994) (interpreting Ind. Appellate Rule 11(B)(3) and reasoning that "summarily affirmed" indicates "that we are declining to review certain issues, in essence a partial denial of transfer").

1997See Kimberlin v. DeLong, 637 N.E.2d 121 , 123 n. 1 (Ind.1994) (interpreting Ind. Appellate Rule 11(B)(3) and reasoning that "summarily affirmed" indicates "that we are declining to review certain issues, in essence a partial denial of transfer”).

22
Orr v. Westminster Village North, Inc.green
ind · 1997 · cited in 3 Indiana opinions naming this issue, 2009–2014
2 sentences

2014In that case, the court explicitly declined the plaintiffs’ invitation to recognize “a broad new exception to the at-will doctrine for employee handbooks.” Orr, 689 N.E.2d at 719 .

2009In Orr v. Westminster Village North, Inc., 689 N.E.2d 712, 722 (Ind.1997), the Indiana Supreme Court "re-affirm[ed] the vitality of the employment-at-will doctrine in Indiana and the general rule that adequate independent consideration is necessary to convert an at-will relationship into an employment relationship requiring an employer to discharge an employee for good cause." It further declined "to construe employee handbooks as unilateral contracts and to adopt a broad new exception to the at-will doctrine for such handbooks." Id.

13
Tony v. Elkhart Countygreen
indctapp · 2006 · cited in 1 Indiana opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Tony v. Elkhart County, 851 N.E.2d 1032 (Ind.Ct.App.2006); Markley Enters, v. Grover, 716 N.E.2d 559, 564-66 (Ind.Ct.App.1999). 4 .

11
Markley Enterprises, Inc. v. Grovergreen
indctapp · 1999 · cited in 1 Indiana opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Tony v. Elkhart County, 851 N.E.2d 1032 (Ind.Ct.App.2006); Markley Enters, v. Grover, 716 N.E.2d 559, 564-66 (Ind.Ct.App.1999). 4 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Wior v. Anchor Industries, Inc. green
ind · 1996
2 sentences

1997We are aware that there has been substantial criticism of the at-will doctrine and a significant amount of commentary and litigation regarding whether employee handbooks constitute valid contracts and, if so, under what circumstances. [12] We are also aware that this Court has not expressly addressed and resolved the question of whether unilateral contracts in the employment context always require adequate independent consideration [13] and whether an *720 employee handbook can ever constitute a unilateral contract serving to modify the otherwise at-will employment relationship. [14] See Wior

1997We are aware that there has been substantial criticism of the at-will doctrine and a significant amount of commentary and litigation regarding whether employee handbooks constitute valid contracts and, if so, under what circumstances. 12 We are also aware that this Court has not expressly addressed and resolved the question of whether unilateral contracts in the employment context always require adequate independent consideration 13 and whether an employee handbook can ever constitute a unilateral contract serving to modify the otherwise at-will employment relationship. 14 See Wior v. Anchor I

21997–1997
Streckfus v. Gardenside Terrace Cooperative, Inc. green
ind · 1987
2 sentences

1997We are aware that there has been substantial criticism of the at-will doctrine and a significant amount of commentary and litigation regarding whether employee handbooks constitute valid contracts and, if so, under what circumstances. [12] We are also aware that this Court has not expressly addressed and resolved the question of whether unilateral contracts in the employment context always require adequate independent consideration [13] and whether an *720 employee handbook can ever constitute a unilateral contract serving to modify the otherwise at-will employment relationship. [14] See Wior

1997We are aware that there has been substantial criticism of the at-will doctrine and a significant amount of commentary and litigation regarding whether employee handbooks constitute valid contracts and, if so, under what circumstances. 12 We are also aware that this Court has not expressly addressed and resolved the question of whether unilateral contracts in the employment context always require adequate independent consideration 13 and whether an employee handbook can ever constitute a unilateral contract serving to modify the otherwise at-will employment relationship. 14 See Wior v. Anchor I

21997–1997
Frampton v. Central Indiana Gas Company green
ind · 1973
1 sentence

2019Ind. Gas Co., 297 N.E.2d 425 (Ind. 1973), wherein our Supreme Court first recognized the public policy exception to the at-will doctrine.

12019–2019

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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