Edmondson v. Shearer Lumber Prods. - 139 Idaho 172, 75 P.3d 733 (2003)

Rule:

In Idaho, the only general exception to the employment at-will doctrine is that an employer may be liable for wrongful discharge when the motivation for discharge contravenes public policy.

Facts:

Michael Edmondson was employed by Shearer Lumber Products for twenty-two years at the company's Elk City mill. In 1999, he became a salaried employee and on his most recent performance review, he received a rating of "very good." However, due to Edmondson’s alleged involvement in activities that were harmful to the long-term interests of Shearer Lumber Products, the company terminated his employment. Edmondson brought an action against Shearer Lumber for wrongful termination of employment and demanded a jury trial. Edmondson moved for partial summary judgment on the claim of termination of employment, asserting breach of the public policy exception to the employment-at-will doctrine. Shearer Lumber moved for summary judgment, claiming that Edmondson, who was at all times material to the complaint an employee-at-will, had no legally cognizable claim regarding his termination. The district court awarded summary judgment to Shearer, holding that Edmondson's allegations did not fall within the limited public policy exception recognized in Idaho. Edmondson appealed, arguing that summary judgment was improperly granted because issues of material fact existed that must be resolved by a jury.

Issue:

Did Shearer Lumber validly terminate Edmondson’s employment, thereby warranting the grant of summary judgment in the employer’s favor?

Answer:

Yes.

Conclusion:

The Court held that Shearer Lumber acted within its rights to discharge Edmondson, who was an at-will employee subject to termination for any reason or for no reason. Because Edmondson did not establish a policy exception to temper the at-will doctrine, neither the method of termination nor its justification was material. According to the Court, there were no facts in evidence supporting a claim of an implied-in-fact contract, and no facts of extreme and outrageous conduct rising to the level of creating a jury issue on the intentional infliction of emotional distress claim. Accordingly, the Court affirmed the order granting Shearer Lumber summary judgment.