Weiner v. McGraw-Hill, Inc.
57 N.Y.2d 458 (1985)
Rule of Law:
An employer's express limitation on its right to terminate an employee at will, found in its personnel handbook or other documents, can be contractually binding if the employee relies on that promise when accepting or continuing employment.
Facts:
- In 1969, McGraw-Hill, Inc. recruited Walton Lewis Weiner, who was then employed at Prentice-Hall.
- During recruitment, a McGraw-Hill representative assured Weiner that the company had a firm policy of not terminating employees without 'just cause,' offering him job security.
- Weiner signed an employment application which stated his employment would be subject to the provisions of McGraw-Hill's personnel handbook.
- The handbook specified that the company would dismiss employees for 'just and sufficient cause only,' and only after rehabilitation efforts had failed.
- Relying on these assurances, Weiner left his job at Prentice-Hall, forfeiting accrued fringe benefits and a proffered salary increase.
- Weiner worked for McGraw-Hill for eight years, receiving promotions and salary increases, and rejected other job offers based on the company's assurances.
- In February 1977, McGraw-Hill discharged Weiner, stating the reason was 'lack of application.'
Procedural Posture:
- Walton Lewis Weiner sued McGraw-Hill, Inc. in the Supreme Court of New York County, a state trial court, alleging breach of contract for wrongful termination.
- McGraw-Hill filed a motion to dismiss the complaint for failure to state a cause of action.
- The trial court (Special Term) denied McGraw-Hill's motion to dismiss.
- McGraw-Hill, as appellant, appealed the trial court's decision to the Appellate Division, an intermediate appellate court.
- A divided Appellate Division reversed the trial court's order and granted McGraw-Hill's motion to dismiss.
- Weiner, as appellant, appealed the Appellate Division's decision to the New York Court of Appeals, the state's highest court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an employer's oral assurance of job security, coupled with a reference in an employment application to a personnel handbook that promises termination only for 'just cause,' create an enforceable contract limiting the employer's right to terminate an otherwise at-will employee?
Opinions:
Majority - Fuchsberg, J.
Yes, these circumstances are sufficient to state a cause of action for breach of contract. The traditional employment-at-will rule is a rebuttable presumption, not an absolute. An employer can be bound by promises of job security made in policy manuals when those promises induce an employee to accept or remain in a position. Here, the combination of McGraw-Hill's oral assurances, the incorporation of the handbook's 'just cause' provision into the employment application, and Weiner's reliance on these promises by leaving his prior job and forgoing other offers, provides sufficient consideration to create a binding contractual limitation on the employer's right to terminate at will. The court rejected the argument that 'mutuality of obligation' was required, finding that Weiner's detrimental reliance constituted valid consideration.
Dissenting - Wachtler, J.
No, these documents and assurances do not create an enforceable contract. Neither the employment application nor the personnel manual contained language indicating an intent to form a binding contract; they were merely expressions of company policy which the employer could unilaterally change. The application was not a contract, and the signatures of company officials were for internal record-keeping, not a contractual exchange. The manual was a conglomerate of broad internal policy guidelines, not a promise. To find a triable issue of fact here would undermine the well-established at-will employment doctrine and create negative public policy consequences by discouraging businesses from operating in New York.
Analysis:
This decision represents a significant exception to New York's historically rigid employment-at-will doctrine. It established that an employer's own written policies, particularly in a personnel handbook, could create an enforceable contract, thereby limiting the employer's absolute right to discharge an employee for any or no reason. The ruling prompted employers to review and often revise their employee handbooks, frequently adding disclaimers to prevent the formation of unintended contracts. This case empowered employees to hold employers accountable for promises of job security, shifting some power in the employer-employee relationship and paving the way for future wrongful discharge litigation based on handbook provisions.
Gunnerbot
AI-powered case assistant
Loaded: Weiner v. McGraw-Hill, Inc. (1985)
Try: "What was the holding?" or "Explain the dissent"