N.D. Cent. Code » Chapter t34c03
North Dakota Century Code

N.D. Cent. Code § 34-03-01 (2026)

Termination of employment at will - Notice required

✓ current as of May 2026
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An employment having no specified term may be terminated at the will of either party on notice to the other, except when otherwise provided by this title.

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Notes of Decisions
Cited in 39 cases (2 in the last 5 years), 1984–2021 · leading case: Hillesland v. Fed. Land Bank Ass'n of Grand Forks, 407 N.W.2d 206 (N.D. 1987).
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Hillesland v. Fed. Land Bank Ass'n of Grand Forks, 407 N.W.2d 206 (N.D. 1987). · cites it 16× “Section 34-03-01, N.D.C.C., is North Dakota's codification of the "at will" doctrine: "Termination of employment at will—Notice required.”
Olson v. Souris River Telecomm. Coop., Inc., 1997 ND 10 (N.D. 1997). · cites it 23× “N.D.C.C. § 34-03-01. Bailey, 398 N.W.2d at 122 .”
Bailey v. Perkins Restaurants, Inc., 398 N.W.2d 120 (N.D. 1986). · cites it 10× “See Section 34-03-01, N.D.C.C. Section 34-03-01 reads as follows: "An employment having no specified term may be terminated at the will of either party on notice to the other, except when otherwise provided by this title.”
Dahlberg v. Lutheran Soc. Serv. Of Nd, 2001 ND 73 (N.D. 2001). · cites it 4× “[¶ 13] Under N.D.C.C. § 34-03-01, employment without a definite term is presumed to be at will, and an at-will employee may be terminated with or without cause.”
Eldridge v. Evangelical Lutheran Good Samaritan Soc'y, 417 N.W.2d 797 (N.D. 1987). · cites it 8× “Section 34-03-01 of the North Dakota Century Code provides as follows: "Termination of employment at will—Notice required.”
Potts v. City of Devils Lake, 2021 ND 2 (N.D. 2021). · cites it 16× “Under N.D.C.C. § 34-03-01, employment without a definite term is presumed to be at will, giving an employer the right to terminate an at-will employee with or without cause.”
Heng v. Rotech Med. Corp., 2004 ND 204 (N.D. 2004). · cites it 4× “[¶ 12] Employment for an indefinite term is governed by N.D.C.C. § 34-03-01: Termination of employment at will— Notice required.”
Kortum v. Johnson, 2008 ND 154 (N.D. 2008). · cites it 4× “Close Corporation Shareholder-Employees and the At-Will Doctrine [¶ 20] When the district court denied Kortum's request for relief, it did not determine whether she was unfairly prejudiced under N.”
Hougum v. Valley Mem'l Homes, 1998 ND 24 (N.D. 1998). · cites it 4× “" We affirm the summary judgment dismissing Hougum's claims against Moran and Sears. IV VMH A [¶ 31] Hougum argues VMH breached a contractual obligation with him.”
Schuhmacher v. North Dakota Hosp. Ass'n, 528 N.W.2d 374 (N.D. 1995). · cites it 4× “NDCC § 34-03-01; Bykonen v. United Hosp., 479 N.”
Anderson v. Meyer Broad. Co., 2001 ND 125 (N.D. 2001). · cites it 2× “1992); see N.D.C.C. § 34-03-01. We have recognized limited public policy exceptions to the at-will rule if employees establish they were terminated in retaliation for complying with a clear public policy.”
Forster v. West Dakota Veterinary Clinic, Inc., 2004 ND 207 (N.D. 2004). · cites it 2× “[¶ 55] We conclude there is sufficient evidence to support the jury’s verdict, and the district court did not commit reversible error in its instructions to the jury or in its evidentiary rulings during the jury trial. Ill [¶ 56] Forster argues the district court erred as a…”
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