Hillesland v. Fed. Land Bank Ass'n - 407 N.W.2d 206 (N.D. 1987)

Rule:

Summary judgment is a procedural device available for the prompt and expeditious disposition of controversies without trial when, after viewing the evidence in a light most favorable to the opposing party and giving that party the benefit of all favorable inferences, there is no genuine dispute as to either the material facts or the inferences to be drawn from undisputed facts.

Facts:

Plaintiff Elmer Hillesland was the Chief Executive Officer of Federal Land Bank Association of Grand Forks. Through his position with the Association, plaintiff learned that certain customers of the Association were experiencing financial difficulties. Plaintiff contacted the customers to offer financial counseling; the customers responded by expressing their desire to sell their farm. The discussions led to an offer to purchase the farm by plaintiff’s sons, which the board of directors approved. The Federal Land Bank of St. Paul’s Review Committee expressed concern over the appearance of a conflict of interest and prohibited any further direct involvement in the transaction by plaintiff. The sale of the land to plaintiff’s sons was completed shortly thereafter. The Bank subsequently launched an investigation into the matter; this led to the termination of plaintiff. Thereafter, plaintiff filed an action against the Association and the Bank, alleging violation of provisions of the Farm Credit Act, 12 U.S.C.S. §§ 2001-2260, breach of contract, age discrimination, and tortious interference with plaintiff's employment contract. The district court granted summary judgment dismissing plaintiff’s action. Plaintiff challenged the decision.

Issue:

Did the trial court err in dismissing plaintiff’s action against the defendants?

Answer:

No.

Conclusion:

The court determined that there was no implied private right of action for wrongful discharge under the Farm Credit Act. Plaintiff's breach of contract claim was properly dismissed because plaintiff was employed at will. Plaintiff failed to raise a genuine issue of material fact on the age discrimination issue. The court found that defendant had the authority to discharge plaintiff and that therefore defendant's discharge of plaintiff could not constitute tortious interference with plaintiff's contract. The court refused to recognize a cause of action for breach of an implied covenant of good faith and fair dealing regarding plaintiff's employment contract. Accordingly, the court affirmed the district court’s grant of summary judgment dismissing plaintiff’s action.