Suburban Hosp., Inc. v. Dwiggins - 324 Md. 294, 596 A.2d 1069 (1991)

Rule:

In Maryland, at-will employment is an employment contract of indefinite duration. It can be legally terminated at the pleasure of either party at any time.

Facts:

William R. Dwiggins claims that Suburban Hospital, Inc. (Suburban) unfairly fired him from his job as a building maintenance supervisor. Following an initial complaint on Dwiggins’ job performance, Dwiggins signed a reinstatement policy and was placed on supervision for six months. Dwiggins was fired shortly thereafter. Dwiggins brought the instant breach of contract action, contending that he was dismissed in violation of the terms of the signed reinstatement agreement. Suburban contended that Dwiggins could be terminated at will. The trial and appellate courts held that the reinstatement agreement was a contractual undertaking and that the hospital limited its otherwise vast discretion to discharge Dwiggins. 

Issue:

Did the imposition of a grievance procedure eliminate the employer's right to terminate an at-will employee?

Answer:

No.

Conclusion:

The court held that at-will employment was an employment contract of indefinite duration that could be legally terminated at the pleasure of either party at any time. Dwiggins’ status before the reinstatement agreement was clearly that of an at-will employee. The court held that Suburban did not intend to make Dwiggins harder to fire when they signed the agreement, which was intended as a disciplinary action.