Guz v. Bechtel National, Inc.
Supreme Court of California
8 P.3d 1089 (Cal. 2000)
Guz (plaintiff) worked at Bechtel (defendant) for over twenty years with raises, promotions, and favorable reviews, under a personnel policy that limited termination for unsatisfactory performance (requiring notice and improvement opportunity) but placed no similar limits on layoffs due to reorganization or reduced work; when Bechtel eliminated Guz's entire work unit and laid him off, he sued claiming an implied for-cause termination contract and a breach of the implied covenant of good faith and fair dealing. The trial court granted Bechtel summary judgment, the court of appeal reversed, and Bechtel appealed.
Whether, under California employment law, the implied covenant of good faith and fair dealing imposes substantive terms and conditions of employment beyond what was actually agreed to by the parties.