Woolley v. Hoffmann-La Roche, Inc.

Woolley (plaintiff), an engineering section head with no separate employment contract, received Hoffmann-La Roche's (defendant) Personnel Policy Manual, which stated employees would only be terminated for cause and set out a rehabilitation procedure before termination. Nearly a decade later, Hoffmann lost confidence in Woolley after piping problems and terminated him without following the manual's procedures. Woolley sued for breach of contract, arguing the manual's termination provision was binding; the trial court and appellate division sided with Hoffmann, treating Woolley as an at-will employee.

Whether, under employment law, an implied promise in an employment manual may transform at-will employment into employment that can only be terminated for cause.