Donahue v. Federal Express Corp.
Superior Court of Pennsylvania
753 A.2d 238 (2000)
Donahue (plaintiff), an at-will FedEx (defendant) employee, complained internally about billing irregularities and was subsequently accused of misconduct and eventually terminated after being denied support, assigned extra duties, and allegedly ordered to falsify data. He unsuccessfully appealed his termination three times through FedEx's internal Guaranteed Fair Treatment Procedure (GFTP), which explicitly disclaimed creating any contractual rights. Donahue then sued, and the trial court granted FedEx's demurrer.
Whether an employer that has not violated public policy and has not received a substantial benefit from, or caused substantial hardship to, an at-will employee owes that employee a duty of good faith and fair dealing when terminating him.