## Facts

- Hollis Case was a local insurance agent who represented three related insurance companies as their agent under written agency contracts.
- The contracts stated that Case acted as an independent contractor, not as an employee.
- Each written contract expressly gave the companies the right to cancel the agency relationship “with or without cause.”
- The companies terminated Case’s agency representation pursuant to the cancellation provisions.
- Case filed suit alleging that the companies’ termination was wrongful and sought damages based on the termination.
- Case also alleged that the companies interfered with his work as their agent, but he did not assert a distinct cause of action based on interference; instead, he tied those allegations to the wrongful-termination theory.
- The companies moved to dismiss for failure to state a claim.
- The trial court granted the motion and dismissed the complaint.
- Case appealed from the dismissal.

## Issues

1. Whether an agent states a claim for wrongful termination when the written agency contracts allow the companies to cancel the agency relationship “with or without cause.”
2. Whether allegations that the companies interfered with the agent’s work, when not pleaded as a separate cause of action, require denial of a motion to dismiss.

## Decision

- The Fifth Circuit affirmed the dismissal for failure to state a claim.
- Because the contracts explicitly allowed cancellation “with or without cause,” the complaint did not state a viable wrongful-termination claim based on the companies’ decision to end the agency relationship.
- Although the complaint included allegations that the companies interfered with Case’s work, those allegations were not presented as an independent basis for relief and did not salvage the wrongful-termination claim.
- The court declined to recast the pleading into a different lawsuit than the one actually asserted.

## Legal Principles

- When a written contract grants a party an express right to terminate the contractual relationship “with or without cause,” exercising that right does not, by itself, support a claim for wrongful termination.
- A complaint may be dismissed under Rule 12 when its own allegations, together with controlling contract language referenced in the pleading, show that the defendant acted within an express contractual authorization.
- Allegations of interference or obstructive conduct do not state a separate claim unless the plaintiff pleads that theory as a distinct cause of action with a clear basis for liability and requested relief; courts are not required to construct unpleaded claims from background allegations.

## Conclusion

The Fifth Circuit affirmed dismissal because Case’s contracts allowed the companies to cancel his agency “with or without cause,” defeating his wrongful-termination theory on the face of the complaint, and his additional allegations of interference were not pleaded as an independent cause of action that could prevent dismissal.


Case v. State Farm Mutual Automobile Insurance Co., 294 F.2d 676 (1961)