Carl v. Children's Hospital, 702 A.2d 159 (1997)

Citation: Carl v. Children's Hospital, 702 A.2d 159 (1997)
Parent Document: Carl v. Children's Hospital, 702 A.2d 159 (1997)
Jurisdiction: DC (municipal)
Effective Date: 1997-09-23
Original Source: https://www.courtlistener.com/opinion/2395626/carl-v-childrens-hospital/ ↗

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This is one of those cases in which the past is prologue. The at-will employment rule *175 states in its unvarnished form that in the absence of a statutory proscription, an employer may discharge an at-will employee for any reason or for no reason. This rule "originated centuries ago as an adjunct to the law of master and servant in England." Weiner v. McGraw-Hill, Inc., 57 N.Y.2d 458, 457 N.Y.S.2d 193, 195, 443 N.E.2d 441, 443 (1982) (footnote omitted). It was, however, soon deemed too rigorous in the land of its birth. "As far back as 1562, England placed statutory limits upon the power of an employer to terminate an employee unless there was `reasonable cause to do so.'" Id., 457 N.Y.S.2d at 196 n. 4, 443 N.E.2d at 443-44 n. 4 (citing 1 WILLIAM BLACKSTONE, COMMENTARIES 131 (1878)). Nineteenth century British courts applied the presumption that an employment relationship was for one year unless the parties had specified otherwise. See Berube v. Fashion Centre, Ltd., 771 P.2d 1033, 1040 (Utah 1989) (citing Note, Implied Contract Rights to Job Security, 26 Stan. L. Rev. 335, 340 (1974)).

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