Boone v. Frontier Refining, Inc
In Boone v. Frontier Refining, Inc., 987 P.2d 681 (Wyo. 1999), the employee, Boone, claimed that the existence of an employment manual created an implied contract for continued employment.
Boone admitted that, although he knew of the existence of the manual, and had seen it on occasion, the employer never gave him a copy and he never read the manual.
The employment manual, in fact, was distributed only to members of management and some supervisors.
The Court applied a contract analysis to determine if the employer had made an offer to Boone to be bound by the terms of the employment manual.
The Court stated that it "looks at the external or objective manifestations of the parties' intentions as revealed by their actions. We determine whether a reasonable man in the position of the offeree would have believed that the other party intended to make an offer." Id. at 687.
The Court determined that "a reasonable person in Boone's position would not have considered the undistributed employment manual to be an offer." 987 P.2d at 687-88.