Skagerberg v. Blandin Paper Co., 197 Minn. 291, 266 N.W. 872 (Minn. 1936)

Facts

  • Rutcher Skagerberg worked as a consulting engineer specializing in heating, ventilating, and air conditioning, earning about $200 per week.
  • He was considering an associate professorship at Purdue University that offered a salary and favorable conditions.
  • Blandin Paper Co., a paper manufacturer, had previously retained him as a consultant at $200 per week and planned substantial plant expansions.
  • Blandin’s officers allegedly offered Skagerberg “permanent employment” at $600 per month if he would reject the Purdue offer and agree to buy the home of the company’s power superintendent.
  • Skagerberg accepted, declined Purdue, began work for Blandin, and later purchased the superintendent’s house.
  • After about twenty-two months, Blandin discharged Skagerberg without cause.
  • Skagerberg sued for wrongful discharge and breach of contract based on an alleged contract for permanent employment.
  • The trial court sustained Blandin’s general demurrer to the amended complaint for failure to state a claim.

Issues

  1. Whether an oral promise of “permanent employment,” without a stated duration, creates employment other than at-will.
  2. Whether rejecting another job offer and purchasing a house constitute “additional consideration” sufficient to make a “permanent employment” promise enforceable as a continuing engagement.

Decision

  • The Minnesota Supreme Court affirmed the order sustaining the demurrer.
  • The court held that “permanent employment,” when the term is indefinite, is presumptively an at-will hiring.
  • The court held that Skagerberg’s alleged reliance (declining Purdue and buying a house) was not the type of independent, valuable consideration that would convert the relationship into enforceable continuous employment.
  • When parties agree to “permanent” employment but specify no definite period, the law treats the hiring as indefinite and terminable at will.
  • “Permanent employment” may be construed as a continuing engagement (so long as the employer has work and the employee performs satisfactorily) only in exceptional circumstances.
  • The exception generally requires the employee to “purchase” the employment with valuable consideration independent of the day-to-day services rendered.
  • Reliance commonly incident to accepting employment—such as turning down other opportunities or relocating/purchasing housing connected to the move—does not, by itself, supply the independent consideration needed to overcome the at-will presumption.

Conclusion

Because the alleged “permanent employment” agreement lacked a definite term and the pleaded facts did not show independent, valuable consideration beyond Skagerberg’s services, the employment was at will and his complaint failed to state a claim for breach based on discharge without cause.