## Facts

- Valarie Brown worked about ten years for Montgomery County Hospital District as a laboratory systems manager.
- Brown’s employment ended after the District terminated her; Brown contended she was fired without good cause and did not resign.
- Brown alleged the hospital administrator told her, at hiring and during employment, she could keep her job as long as she did her job and would not be fired without “good reason” or “good cause.”
- Brown asserted these statements induced her to relocate for the position and created an oral “good cause” employment contract limiting termination.
- Brown sued for breach of alleged oral and written employment contracts and for deprivation of property and liberty interests under the Texas Constitution.
- The trial court granted summary judgment for the District on all claims; the court of appeals agreed the employee manual was not a contract but reversed as to the alleged oral contract.

## Issues

1. Whether an employer’s oral assurances that an employee will not be terminated without “good reason” or “good cause,” without more, modify Texas at-will employment and create an enforceable for-cause contract.

## Decision

- The Supreme Court of Texas reversed the court of appeals and reinstated the trial court’s summary judgment for the District.
- The court held that the alleged oral assurances, standing alone, did not modify Brown’s at-will status.
- Because the statements were legally insufficient to create a for-cause contract, no genuine issue of material fact existed on the oral-contract claim.

## Legal Principles

- In Texas, employment for an indefinite term is presumed at-will and may be terminated by either party at any time, for any reason, absent an agreement to the contrary.
- At-will status is not altered by an employer’s oral statements unless the employer shows a definite, stated intention to be bound to limit termination.
- General oral assurances of continued employment based on satisfactory performance or “good cause” are too indefinite to constitute an express and unequivocal agreement restricting termination.
- Without an enforceable limitation on termination, claims dependent on a contractual entitlement to continued employment fail as a matter of law on summary judgment.

## Conclusion

The Texas Supreme Court held that generalized oral job-security assurances do not, by themselves, create a for-cause employment contract or overcome the presumption of at-will employment, and it rendered judgment for the employer by reinstating summary judgment.


Montgomery Cnty. Hosp. Dist. v. Brown, 965 S.W.2d 501 (Tex. 1998)