Pat Choate v. Trw, Inc

Citations: 14 F.3d 74; 304 U.S. App. D.C. 312; 9 I.E.R. Cas. (BNA) 382; 1994 U.S. App. LEXIS 1713; 1994 WL 27879Docket: 92-7107

Court: Court of Appeals for the D.C. Circuit; February 4, 1994; Federal Appellate Court

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Pat Choate appealed a summary judgment from the U.S. District Court for the District of Columbia, which ruled in favor of his former employer, TRW, Inc., in a wrongful discharge lawsuit. Choate's claims were based on breach of contract and promissory estoppel. The court affirmed the summary judgment, stating there was no evidence to counter the presumption of at-will employment or to support a promissory estoppel claim.

Choate had worked at TRW from 1981 until his termination in 1990, rising to Vice President of the Office of Policy Analysis. His troubles began after he publicly addressed foreign influence in American politics, which conflicted with TRW's business interests due to its dealings with Japanese clients. TRW terminated him, citing these concerns.

Choate initially sued for $30 million, claiming his employment contract limited termination to specific conditions, none of which included his writings. TRW argued that even accepting Choate's account, there was no basis for his claims. The District Court ruled in favor of TRW, leading to the appeal, which reinforced that employment of indefinite duration is generally considered at-will, allowing termination by either party without cause.

The District Court acknowledged uncertainty regarding whether the employment relationship was governed by District of Columbia law or Virginia law, the latter being where TRW's offices are located. However, since both jurisdictions are 'at will,' a choice of law is unnecessary. In an at-will context, a plaintiff like Choate must overcome the presumption of at-will employment by demonstrating a 'clearly expressed' contractual intent from both parties. Choate failed to provide such evidence, as the summary judgment record contradicted his claims and supported the at-will presumption. Specifically, TRW's letter confirming Choate's employment outlined salary and benefits but did not specify a term of employment, instead indicating a 'long term basis' consistent with at-will employment's indefinite duration. Additionally, Choate signed an Employee Confidential Information Agreement that acknowledged TRW as the employer for a mutually agreeable time and received a Policy Manual stating TRW could terminate any employee at any time. Although Choate contended he had evidence to counter the presumption, the court noted that the burden of proof lies with the nonmoving party at trial. TRW's argument relied on the absence of evidence supporting a 'clearly expressed' contractual intent. Choate argued his understanding of non-terminable employment was based on TRW's language and his resignation from a secure government job to accept the position.

The assertions made by Choate, while potentially disputable, are deemed non-material and do not impact the litigation's outcome. The court confirmed that, in cases lacking clearly expressed contrary intent, employment is presumed to be at-will, even if described as 'permanent.' The District Court correctly granted summary judgment on both the breach of contract and promissory estoppel claims. For promissory estoppel to apply, a promise must be one that the promisor reasonably expects to induce substantial action or forbearance from the promisee. TRW demonstrated that there was no genuine issue of material fact regarding the existence of such a promise or the necessary elements of reasonable expectation and inducement. Choate’s reliance on a statement from TRW's CEO was found insufficient, as it did not constitute a clear expression of intention or commitment. Consequently, the summary judgment was upheld. Additionally, Choate's negligence claim was dismissed as frivolous, lacking specific allegations of negligent acts or duties breached, with the court affirming the summary judgment on this claim as well. The document notes that Virginia's rules regarding at-will employment align with those of the District of Columbia, affirming the District Court's presumption of at-will employment due to the absence of evidence indicating a different intended duration.