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Slifkin v. Condec Corp.

Citations: 13 Conn. App. 538; 538 A.2d 231; 1988 Conn. App. LEXIS 79Docket: 5544

Court: Connecticut Appellate Court; March 1, 1988; Connecticut; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by the plaintiff, challenging a judgment favoring the defendant in a wrongful discharge lawsuit. The plaintiff, a former general counsel, claimed breach of an employment contract that allegedly guaranteed a minimum twelve-year term for full vesting in benefit plans. The trial court, guided by a referee's report, ruled against the plaintiff, accepting that the employment depended on satisfactory performance. The plaintiff's complaint included claims of breach of contract, promissory estoppel, and breach of the implied covenant of good faith. The appellate court, however, identified an error in the trial court's acceptance of the referee's report, which incorrectly implied a satisfactory performance condition not present in the written agreement. The written contract, dated June 4, 1979, confirmed an oral agreement, offering employment sufficient for vesting benefits, and did not stipulate termination based on performance. The court determined the contract specified a fixed term, allowing termination only for 'good cause.' Consequently, the previous judgment was vacated, and the case was remanded for a new trial, highlighting the importance of adhering to the explicit terms of employment agreements without unwarranted conditions.

Legal Issues Addressed

Contractual Requirement of 'Good Cause' for Termination

Application: The court concluded that employment could only be terminated for 'good cause' when the contract specifies a definite period, rejecting the notion of termination for unsatisfactory performance without such cause.

Reasoning: The court concluded that the plaintiff’s employment could only be terminated for such good cause, rejecting the trial referee's finding that the contract was indefinite and could be terminated for unsatisfactory performance.

Implied Covenant of Good Faith and Fair Dealing

Application: The plaintiff claimed that the defendant breached the implied covenant by falsely inducing him to leave his previous employer, seeking punitive damages.

Reasoning: The fourth count asserted a breach of the implied covenant of good faith, claiming the defendant falsely induced him to leave Shell, and sought punitive damages and attorney’s fees.

Interpreting Employment Contract Duration and Conditions

Application: The court found error in adding an implied condition of satisfactory performance to an employment contract that specified a fixed term for vesting in benefit plans.

Reasoning: The court incorrectly added this condition. The attorney trial referee found that the original agreement was entirely oral and that the June 4, 1979, agreement served as a written confirmation of that prior oral understanding.

Promissory Estoppel in Employment Contracts

Application: The plaintiff asserted that the defendant's promises induced him to leave his previous long-term employer, invoking promissory estoppel due to reliance on assurances of employment.

Reasoning: The second count of promissory estoppel argued that the plaintiff, then 55 years old, was hesitant to leave his long-term role at Shell Oil Company without assurance of sufficient employment from the defendant, which the defendant was allegedly aware of.

Wrongful Discharge and Breach of Employment Contract

Application: The case addresses the wrongful discharge claim based on an alleged breach of an employment contract that guaranteed continued employment for a fixed period to achieve full vesting in benefit plans.

Reasoning: The breach of contract claim alleged that the defendant agreed to employ the plaintiff as general counsel with a guaranteed salary, bonuses, and participation in benefit plans for a minimum of twelve years to achieve full vesting.