## Facts

- Kenneth Harrison was recruited to join an insurance brokerage and consulting firm to head and reorganize its marketing department.
- During pre-employment discussions, Harrison asked how long it would take to “work out the bugs” in reorganizing the department; his supervisor stated that about a year would be appropriate.
- Harrison concluded he would need roughly six months to learn the department before reorganizing it and later claimed these discussions implied “at least two years” of employment.
- Harrison admitted in deposition testimony that the supervisor never promised him a definite term of employment.
- Harrison began work and, about six months later, his supervisor became dissatisfied with his performance and terminated him.
- Harrison sued in diversity, alleging breach of an oral two-year employment contract and wrongful discharge based on a “just cause” requirement.
- Defendants moved for summary judgment.

## Issues

1. Whether the pre-employment conversations created an enforceable two-year employment contract or instead left the employment relationship at-will under Pennsylvania law.
2. Whether an at-will employee may assert wrongful discharge based on an asserted “just cause” limitation absent a recognized public-policy exception.
3. Whether the record contained evidence of fraud or misrepresentation sufficient to affect the contract analysis or defeat summary judgment.

## Decision

- The court granted summary judgment for the defendants on all claims.
- The court held no enforceable two-year employment contract existed because there was no clear, definite promise of duration; the employment was at-will.
- The court held the wrongful-discharge claim failed because Pennsylvania law does not impose a general “just cause” requirement on at-will employment and no applicable public-policy exception was shown.
- The court found the record did not support a fraud or misrepresentation theory based on specific false statements of material fact.

## Legal Principles

- In Pennsylvania, employment for an indefinite duration is presumed at-will and terminable by either party at any time absent a clear, definite agreement to the contrary.
- A plaintiff’s subjective expectation about employment duration is insufficient to prove a definite-term contract; the promise must be explicit and definite.
- Statements estimating the time needed to complete a task or reorganization, without more, are projections and do not establish a minimum employment term.
- At-will employees generally lack a wrongful-discharge claim unless the termination violates a clearly mandated public policy recognized by Pennsylvania law.
- To rely on fraud or misrepresentation, a party must present specific evidence of a false representation of material fact, intent to deceive, reliance, and resulting injury.

## Conclusion

The court concluded that discussions about how long a reorganization might take did not create a definite-term employment contract, leaving Harrison an at-will employee; because no recognized public-policy exception or actionable fraud was shown, the defendants were entitled to summary judgment.


Harrison v. Fred S. James, P.A., Inc., 558 F. Supp. 438 (E.D. Pa. 1983)