Loghry v. Unicover Corp

In Loghry v. Unicover Corp., 927 P.2d 706, 712 (Wyo. 1996), the employee contended that the special relationship existed by virtue of separate consideration given when she turned over files to a vice president (Hilt) of her employer's sister corporation and did not inform her supervisor that the supervisor was the object of an investigation. In rejecting Loghry's claim, the Court wrote: "Loghry's assertion that she acted when she did not have to does not constitute valid consideration since there is no dispute that she was required to turn over company documents at the request of a company officer. She does not contend that she gave up an obligation to inform her supervisor of Hilt's request. Without a demonstration of legal detriment, Loghry does not establish the existence of separate consideration." 927 P.2d at 712. To establish separate consideration, the Loghry court thus required something more than merely performing the duties of the job.