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
- Whether an oral promise of “permanent employment,” without a stated duration, creates employment other than at-will.
- 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.
Legal Principles
- 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.