Should a Case Where an Employer Makes Changes in Employee Handbook to the Disadvantage of Employees be Decided on Contract Law Principles ? In Doyle v. Holy Cross Hospital, 186 Ill. 2d 104, 110, 708 N.E.2d 1140, 237 Ill. Dec. 100 (1999), which was decided by the Illinois Supreme Court in 1999, the issue before the court was whether an employer could make unilateral changes to provisions in an employee handbook, in the absence of a previous reservation of the right to do so, that would operate to the disadvantage of existing employees. Doyle v. Holy Cross Hospital, 186 Ill. 2d 104, 110, 708 N.E.2d 1140, 237 Ill. Dec. 100 (1999). The majority first considered Duldulao v. Saint Mary of Nazareth Hospital Center, 115 Ill. 2d 482, 505 N.E.2d 314, 106 Ill. Dec. 8 (1987), in which the court had first recognized the enforceable effect of employee handbook provisions, and on the basis of Duldulao the majority concluded that after an employer is contractually bound to the provisions of an employee handbook, an attempted unilateral modification of its terms by the employer to an employee's disadvantage fails for a lack of consideration. Doyle, 186 Ill. 2d at 112-13. In other words, the Doyle majority decided the issue before it on the basis of contract law principles. Indeed, the majority declined to address at all the issue of promissory estoppel. Doyle, 186 Ill. 2d at 117. Then-Chief Justice Freeman, joined by Justice McMorrow, concurred in part with and dissented in part from the majority's disposition. Justice Freeman agreed with the majority that a contract existed, and he agreed that the case should be decided on contract law principles. Doyle, 186 Ill. 2d at 118 (Freeman, C.J., concurring in part and dissenting in part, joined by McMorrow, J.).