VanLente v. University of Wyoming Research Corp.
975 P.2d 594, 1999 Wyo. LEXIS 38, 14 I.E.R. Cas. (BNA) 1732 (1999)
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Rule of Law:
Wyoming law does not recognize a contract-based cause of action for breach of the implied covenant of good faith and fair dealing in an at-will employment relationship. A tort claim for such a breach is available only in rare circumstances where a 'special relationship' of trust and reliance exists between the employer and employee, which requires more than mere longevity of service.
Facts:
- William D. VanLente was employed by the Western Research Institute Corporation (the Institute) as a Human Resources Manager for approximately nine years.
- James G. Speight, the Institute's Chief Executive Officer, allegedly threatened VanLente's employment on three separate occasions.
- Speight's threats were allegedly in response to VanLente's refusal to assist Speight in retaliating against another employee who had filed a complaint with the Equal Employment Opportunity Commission.
- VanLente claimed his work environment became hostile and his responsibilities were increased in an effort to make him appear incompetent.
- In the summer of 1992, the Institute conducted a reduction-in-force due to budgetary constraints.
- VanLente was terminated as part of this reduction-in-force.
- VanLente believed Speight included him in the reduction-in-force to carry out the previous threats against his job.
Procedural Posture:
- VanLente first filed a claim with the United States Equal Employment Opportunity Commission, which issued an adverse determination.
- VanLente then filed a lawsuit in the United States District Court for the District of Wyoming, which was later dismissed for his failure to prosecute.
- VanLente subsequently filed this action in the District Court of the Second Judicial District of Wyoming against the Institute and Speight.
- The defendants filed a Motion for Summary Judgment.
- The state district court (trial court) granted summary judgment in favor of the defendants, holding that Wyoming law does not recognize a contract claim for breach of the implied covenant of good faith and fair dealing, and that VanLente failed to establish a 'special relationship' for a tort claim.
- VanLente (Appellant) appealed the trial court's grant of summary judgment to the Supreme Court of Wyoming.
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Issue:
Does Wyoming law recognize a contract-based cause of action for breach of the implied covenant of good faith and fair dealing for an at-will employee?
Opinions:
Majority - Justice Thomas
No. Wyoming law does not recognize a contract remedy for the breach of the implied covenant of good faith and fair dealing in an at-will employment relationship. The court reasoned that since Wyoming is an employment-at-will state, there is no underlying contract to which a covenant of good faith and fair dealing can attach. To recognize such a remedy would be to create a contract where none exists. The court affirmed its precedent that an at-will employee's remedies for wrongful termination are limited to tort claims, such as retaliatory discharge against public policy or a breach of the implied covenant where a rare 'special relationship' can be proven. In this case, VanLente's nine years of service and his position's sensitive duties were insufficient to establish such a special relationship.
Analysis:
This decision solidifies Wyoming's strict adherence to the employment-at-will doctrine, refusing to create a contract-based exception for bad-faith terminations. By doing so, the court maintains a clear distinction between contract law and tort law in the employment context. The ruling also reinforces the high bar for establishing the 'special relationship' required for a tort claim, making it exceedingly difficult for at-will employees to succeed on such claims and preserving broad employer discretion in termination decisions.
