Sanders v. FedEx Ground Package System
Supreme Court of New Mexico
188 P.3d 1200 (2008)
Ken Sanders (plaintiff) worked as an independent contractor for FedEx Ground (defendant) making deliveries, and though his contract didn't explicitly say so, he claimed FedEx represented during negotiations that independent contractors could purchase additional delivery routes from other contractors. When Sanders twice sought to buy additional routes, FedEx refused both times, and he sued for breach of contract and breach of the implied covenant of good faith and fair dealing; the jury ruled for Sanders, and FedEx appealed, arguing no express contract term granted a right to purchase routes, and the court of appeals reversed.
Whether the implied covenant of good faith and fair dealing protects benefits that are inferred from the express terms of a contract, even without an explicit provision granting them.