On the Edge: Employment at Will at Howmet Corporation?
Nancy Lytle thought her job as a general clerk in the human resources department of Howmet Corporation in Michigan was secure. When she was hired she got an employee handbook with all the companys employment policies. On the first page of the handbook it stated:
The contents of this booklet are not intended to establish, and should not be interpreted to constitute any contract between . . . Howmet Corporation and any employee, or group of employees.
A few pages later the handbook stated:
No employee will be terminated without proper cause or reason and not until management has made a careful review of the facts.
At one point she told her supervisor she was thinking of resigning. He responded that the company would not fire her without a proper reason and she was in line for further promotions. She had already received two promotions and had consistently received favorable performance evaluations. A while later her supervisor retired and a new supervisor took over. The new supervisor told Nancy and the other girls that they should wear dresses at the company picnic. Nancy refused. Her new supervisor gave Nancy her first bad evaluation, and subsequently fired her. Nancy had worked for the company for 20 years. Nancy sued because she felt her employer had no right to terminate her except for a proper reason. The first court that heard her case agreed with her. The case was appealed to the Michigan Supreme Court, whose justices disagreed among themselves but a majority of whom held her employer had no right to fire her. The case was returned to a lower court, which could not resolve all the issues. The Michigan Supreme Court again heard the case, and this time a majority held her employer had the right to fire her.