In Edwards v. Geisinger Clinic, the Third Circuit Court of Appeals had an opportunity to rule on whether a physician had alleged sufficient evidence to support his breach of contract claim following his termination after roughly one year of employment. In Edwards, the physician believed that he was guaranteed employment at least until he completed the four-year program necessary for his board certification. The court rejected the physician’s argument upholding the dismissal of his complaint. The court reasoned that in order to overcome the presumption of employment at-will, a party must demonstrate with “clear and precise evidence” that the parties intended to enter into an employment contract for a definite term. The court noted that an employee’s “subjective expectation” of employment for a definite term does not demonstrate that there was in fact an employment contract for a definite term. Similarly, an employer’s “hope” that an employee would remain employed for a certain time would not demonstrate the existence of an employment contract for a set term. Thus, this case seems to evidence Pennsylvania’s strong presumption of employment at-will and the need to clearly set forth in the terms of a document a party’s desire to enter into an agreement for employment for a set period of time.
Thanks to Colleen Hayes for her contribution to this post.