Brodie v. General Chemical Corp
In Brodie v. General Chemical Corp., 934 P.2d 1263 (Wyo. 1997), the employee began work governed by a handbook containing promises implying job security.
Some time later in the course of his employment, the employer attempted to revoke the handbook to restore at-will status.
The question presented was whether additional consideration was required when an employer modifies an implied job security provision to restore at-will status.
Under the facts presented, the court answered the question in the affirmative.
However, in determining whether there was sufficient consideration to support the revocation as it occurred in that case, the court expressly distinguished representations made after employment begins from those made at the time employment begins.
The court said:
"Our analysis today assumes that the representations are made after employment has begun and is, therefore, a modification. A different situation is presented when the representation is made at the time that employment begins. In that case, the representation, if enforceable, is a term of the implied employment contract along with the other usual terms specifying pay, benefits, working hours, and job responsibilities under the rule that a single consideration can support several promises." (Brodie, 934 P.2d at 1265 n.1.)