At-Will Employment Contract Case In New Mexico

In this termination of a professional services contract case, we review our Supreme Court's holding in Melnick v. State Farm Mutual Automobile Insurance Co., 106 N.M. 726, 749 P.2d 1105 (1988), declining to recognize a claim for breach of an implied covenant of good faith and fair dealing in an at-will employment contract.

In Bourgeous v. Horizon Healthcare Corp., 117 N.M. 434, 438, 872 P.2d 852, 856 (1994), our Supreme Court described its holding in Melnick both as having "declined to recognize a cause of action in an at-will contract for breach of an implied covenant of good faith and fair dealing," and as having "declined to 'apply an implied covenant of good faith and fair dealing to override express provisions addressed by the terms of an integrated written contract.'" Bourgeous, 117 N.M. at 438, 872 P.2d at 856 (quoting Melnick, 106 N.M. at 731, 749 P.2d at 1110).