Adams v. Hercules, Inc
In Adams v. Hercules, Inc., 245 Ga. 464 (265 SE2d 781) (1980), an employee filed suit to recover benefits allegedly owed under the company's voluntary supplemental payment plan.
Although the company's master agreement contained a provision limiting the payment of the benefits, no such limitation was mentioned in the company's handbook delivered to newly hired employees.
Based upon these circumstances, the Court was called upon to determine whether, as a matter of law, the company was bound by the incomplete information in its handbook, or whether the handbook provided adequate notice that the employee should consult the master agreement as another source to determine the full details for the available benefits. Id. at 464-465.
The evidence showed that in addition to generally describing the employee benefits, the handbook contained statements explaining that the benefit plans were presented "in a very brief form" and instructed employees to "obtain the full details of all Benefit Plans from your Foreman, Supervisor or the Personnel Department." Adams, 245 Ga. at 465.
The Court ruled that "this language, even if standing alone, would put the ordinarily prudent person on notice that the complete details were absent from this presentation, and that at least one other source should be consulted for full details." Id.
As such, the employee was not entitled to rely exclusively upon the handbook; rather, the employee had adequate notice that he was required to make further inquiry into the full details of the benefit plans provided in the master agreement, as the handbook had instructed him to do. Id.