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Harden v. Maybelline Sales Corp.

Citations: 230 Cal. App. 3d 1550; 282 Cal. Rptr. 96Docket: A049299

Court: California Court of Appeal; June 6, 1991; California; State Appellate Court

Narrative Opinion Summary

In the case of Steven E. Harden v. Maybelline Sales Corporation, the California Court of Appeals examined a wrongful termination claim brought by the plaintiff against his former employer. The central issue revolved around whether the employment arrangement was at-will or whether an implied contract existed, requiring good cause for termination. Initially, the trial court granted summary judgment in favor of Maybelline, relying on an at-will clause in the plaintiff's standardized employment application. Harden contended his termination was unjust, citing assurances of job security and the absence of at-will terms in his formal job offer. The appellate court found that an at-will clause in a preprinted application does not preclude consideration of an implied contract when supported by evidence, and reversed the trial court’s decision. The court highlighted that material factual disputes existed, particularly regarding the existence of an implied contract. Consequently, summary judgment was deemed inappropriate, and costs were awarded to the plaintiff. The Supreme Court declined to review the case, and the decision was certified for publication, with one justice dissenting. The outcome underscores the necessity of a thorough examination of employment terms beyond standardized application language in wrongful termination disputes.

Legal Issues Addressed

At-Will Employment and Implied Contracts

Application: The court found that an at-will clause in a preprinted application does not automatically negate a claim for an implied contract requiring termination only for good cause.

Reasoning: The court found that the at-will employment clause in a preprinted application could not solely negate a claim for an implied contract that required termination only for good cause.

Integration Clause in Employment Agreements

Application: An employment application lacking essential terms or an integration clause cannot be considered an integrated agreement.

Reasoning: Conversely, the plaintiff cites McLain v. Great American Ins. Companies, positing that a standardized application lacking essential employment terms or an integration clause cannot be considered an integrated agreement.

Presumption of At-Will Employment

Application: The presumption of at-will employment can be rebutted by evidence of an express or implied agreement that limits the employer's termination power.

Reasoning: The presumption of at-will employment can be rebutted if there is evidence of an express or implied agreement limiting the employer's termination power.

Summary Judgment Standards

Application: Summary judgment is appropriate only when there are no material fact issues or when the law dictates a cause of action cannot succeed.

Reasoning: In reviewing the case, it is established that summary judgment is appropriate only when no material fact issues exist or when the law dictates a cause of action cannot succeed.