## Facts

- Corey Loghry worked for Unicover Corporation as an administrative assistant and sometimes assisted with creative projects.
- At hiring, Loghry signed a written disclaimer stating her employment could be terminated at any time, with or without cause or notice; the employee handbook contained a similar disclaimer.
- The disclaimer further stated only the company president could modify the terms of employment or create employment for a specified period.
- Loghry helped develop a project that later appeared in similar form through a competitor, leading Unicover to investigate a suspected internal leak.
- A corporate officer (not the president) requested that Loghry turn over her project files; Loghry expressed concern about cooperating in an investigation involving her supervisor and about losing her job.
- The officer assured Loghry she would not lose her job if she cooperated, and she provided the files.
- After cooperating, Loghry was terminated, allegedly for “lack of loyalty” to her supervisor.
- After an earlier appeal confirmed her at-will status, Loghry pursued new claims for promissory estoppel, breach of the covenant of good faith and fair dealing (contract and tort theories), and punitive damages; the district court granted summary judgment for Unicover on all claims.

## Issues

1. Whether conspicuous written at-will disclaimers made Loghry’s reliance on a later oral assurance of job security unreasonable as a matter of law, defeating promissory estoppel.
2. Whether Wyoming recognizes a contractual cause of action for breach of the implied covenant of good faith and fair dealing in an at-will employment relationship.
3. Whether the evidence showed a “special relationship of trust and reliance” sufficient to support a tort claim for breach of the implied covenant of good faith and fair dealing, and thus punitive damages.

## Decision

- The Wyoming Supreme Court affirmed summary judgment for Unicover on all claims.
- Promissory estoppel failed because the signed and acknowledged disclaimers preserved at-will employment and limited modification authority to the president, making reliance on a non-president’s contrary oral promise unreasonable as a matter of law.
- The contractual covenant claim failed because Wyoming does not recognize a standalone contract claim for breach of the implied covenant in the employment-at-will context.
- The tort covenant claim failed because Loghry did not show a special relationship of trust and reliance; her cooperation in the investigation was not separate consideration or an extraordinary relationship beyond ordinary employment.
- Punitive damages failed because there was no surviving underlying tort claim.

## Legal Principles

- Promissory estoppel requires reasonable reliance; clear, conspicuous, and acknowledged at-will disclaimers can render reliance on later inconsistent oral assurances unreasonable as a matter of law.
- In Wyoming employment law, the implied covenant of good faith and fair dealing does not create a standalone contractual cause of action that alters an at-will relationship or overrides explicit at-will disclaimers.
- A tort claim for breach of the implied covenant in employment is available only in rare circumstances requiring a special relationship of trust and reliance beyond ordinary at-will employment; routine cooperation with employer directives is insufficient.
- Punitive damages are unavailable absent an independent, viable tort claim.

## Conclusion

The court held that Unicover’s effective at-will disclaimers barred Loghry’s promissory-estoppel theory, Wyoming law did not permit her contractual good-faith claim, and the record did not support the special-relationship requirement for a tort good-faith claim, requiring affirmance of summary judgment and dismissal of punitive damages.


Loghry v. Unicover Corp., 927 P.2d 706 (Wyo. 1996)