Lawlis v. Kightlinger & Gray
Indiana Court of Appeals
562 N.E.2d 435 (1990)
Lawlis (plaintiff), a senior partner at law firm Kightlinger & Gray (K&G) (defendant), developed an alcohol problem in 1982 and, after disclosing it, had his work units reduced and signed a Program Outline stating there would be "no second chance" if he drank again; he relapsed in 1984, but K&G gave him another chance to remain senior partner if he stopped drinking permanently, which he did. Two years later, when Lawlis sought increased work units, K&G's Finance Committee instead recommended severing his senior partnership by mid-1987, a recommendation the senior partners approved over Lawlis's objection, ultimately voting to expel him in early 1987 after he refused a proposed addendum reducing his status; Lawlis sued, alleging K&G breached its implied duty of good faith by expelling him for the "predatory purpose" of raising the firm's partner-to-lawyer ratio and partner profits, citing an internal memo recommending exactly that ratio increase, and the district court granted K&G summary judgment.
Whether a partnership acts in bad faith by expelling an unproductive partner who violated terms and conditions to which that partner agreed.