January 05, 2009
Interesting At-Will Employment Case from West Virginia
As reported in the West Virginia Record, Williamson Memorial Hospital hired Crystal Hatfield in 2005 as a benefits and special projects coordinator. Her wage -- $14/hour -- angered other employees who had not applied for the position because they were told it would pay only $7-9/hour. Rumors swirled that Hatfield lacked the requisite qualifications for the job and that her hiring was the result of nepotism. The hospital administration was facing a mutiny and so the responsible parties decided to fire Hatfield after she had worked at the hospital only four days. She sued, claiming breach of contract, among other things.
On December 12th, in a per curiam opinion, the West Virginia's Supreme Court of Appeals, affirmed the dismissal of Hatfield's claims based on its view that Hatfield was an at-will employee. Ms. Hatfield alleged a promise for long-term employment based on an offer letter citing an annual salary of $29,120 and informing Ms. Hatfield of the hospital's employee benefits program. The court found nothing in the letter suggesting anything other than an offer of at-will employment and thus dismissed Ms. Hatfield's breach of contract claim. The court dismissed her claim for breach of the duty of good faith and fair dealing in a few brief paragraphs, noting that West Virginia does not recognize any such duty in the context of at-will employment. And since Ms. Hatfield was apprised of her at-will status, the court also rejected her claim based on detrimental reliance.
In order to take the position with Williamson Memorial, Ms. Hatfield had resigned a position at a firm in Charleston that paid her $12/hour. After she lost her position at Williamson, she was unemployed for five months before her old firm re-hired her. Unless Ms. Hatfield was somehow a party to a scheme to hire her for a position for which she was unqualified, it seems clear that an injustice was done to her, but it may well be the sort of injustice that law courts cannot address.
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