Foley v. Interactive Data Corp.
Supreme Court of California
765 P.2d 373 (1988)
Daniel Foley (plaintiff) worked nearly seven years for Interactive Data Corporation (IDC) (defendant), earning strong evaluations, bonuses, and a promotion, while IDC maintained termination guidelines requiring a seven-step pre-termination process. After Foley reported to a vice president that his new supervisor was under FBI investigation for embezzlement, the vice president dismissed it as rumor; Foley was soon told he was being replaced and was ultimately asked to resign or be fired. Foley sued for wrongful discharge in violation of public policy, breach of an implied contract, and breach of the implied covenant of good faith and fair dealing; the trial court dismissed all claims, and the appellate court affirmed before the California Supreme Court took review.
Whether an at-will employment arrangement may be modified by an implied contract arising from the employer's policies and specific statements made to the employee.