McDonald v. Mobil Coal Producing, Inc.
Supreme Court of Wyoming
820 P.2d 986 (Wyo. 1991)
McDonald (plaintiff), an at-will employee of Mobil Coal Producing (Mobil) (defendant), was told by his supervisor to "do his job and not worry" about rumors of sexual harassment, but was later given the choice to resign or be fired. He resigned and sued for breach of contract, pointing to Mobil's employee handbook, which stated in plain, inconspicuous text that it was not an employment contract but which also promised "individual consideration" and "free and open communications" to resolve workplace disputes and contained disciplinary procedures. The trial court granted Mobil summary judgment, the Wyoming Supreme Court initially reversed, and the court then granted Mobil's motion for rehearing.
Whether a genuine issue of material fact exists as to whether a contract was formed by an employee handbook that inconspicuously disclaims being an employment contract while also containing language that could induce reasonable reliance on it as one.