Snow v. Mike Bloomberg 2020, Inc., 4:20-cv-00490

Background:

Plaintiff Gregory Snow was hired in Feb 2020 as a field organizer for Mike Bloomberg 2020, Inc.; he signed an offer letter and employee handbook that both expressly stated his employment was "at will" and that oral modifications were not binding.
Snow alleges public and interview statements promising employment through the November 2020 election induced him to accept the job and forego other opportunities.
Bloomberg exited the presidential race on March 4, 2020; Snow was terminated March 10, 2020 (paid through March) and sued for breach of contract, promissory estoppel, fraud/fraudulent inducement, unjust enrichment, and FLSA overtime unpaid wages.
Defendant moved for summary judgment, arguing the written at-will agreement bars contract modification/reliance, the economic-loss rule and lack of justifiable reliance bar tort claims, unjust enrichment is unavailable given an express contract, and the FLSA does not cover the campaign or Snow.
The magistrate judge granted summary judgment for Defendant on all claims, holding the written documents controlled, reliance was unjustified, tort claims were barred where the contract governed, and FLSA coverage was lacking.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of contract	Oral/public promises (and interview statements) guaranteed employment through Nov 2020 and modified the written at-will agreement	Offer letter & handbook expressly made employment at-will and forbade oral modifications; parol evidence inadmissible	Court: Written at-will agreement controls; oral/public statements contradict it; no breach as matter of law; SJ for defendant
Promissory estoppel	Promise of employment is enforceable; Snow relied to his detriment	An express written contract governs subject matter; disclaimers make reliance unreasonable	Court: Promissory estoppel barred by existing written contract and reliance was unreasonable; SJ for defendant
Fraud / fraudulent inducement	Defendant misrepresented job duration, inducing Snow to accept employment	Economic-loss rule bars tort for contract-related losses; written disclaimers negate justifiable reliance	Court: Fraud claims barred by economic-loss rule and lack of justifiable reliance; SJ for defendant
Unjust enrichment	Campaign was enriched by promises and Snow's work; equity requires remedy	Valid express contract exists; Snow was paid for work; no evidence of unjust benefit beyond contract	Court: Unjust enrichment unavailable where express contract governs and no causal proof of unjust benefit; SJ for defendant
FLSA overtime	Snow worked overtime and campaign engaged in interstate commerce so FLSA covers him	Campaign not a covered "enterprise" (political, not commercial); Snow not individually engaged in interstate commerce	Court: No FLSA coverage for enterprise or individual; SJ for defendant

Key Cases Cited

Manning v. Upjohn Co., 862 F.2d 545 (5th Cir. 1989) (written agreement required to limit at-will discharge)
Lumpkin v. H & C Commc’ns, Inc., 755 S.W.2d 538 (Tex. App.—Houston [1st Dist.] 1988) (parol evidence and at-will employment principles)
Cnty. of Dallas v. Wiland, 216 S.W.3d 344 (Tex. 2007) (limitations on inferring restrictions to at-will employment)
Montgomery Cnty. Hosp. Dist. v. Brown, 965 S.W.2d 501 (Tex. 1998) (oral assurances insufficient to modify at-will status absent definite intent)
LAN/STV v. Martin K. Eby Const. Co., Inc., 435 S.W.3d 234 (Tex. 2014) (economic-loss rule limits tort recovery for contract-based economic harms)
Sw. Bell Tel. Co. v. DeLanney, 809 S.W.2d 493 (Tex. 1991) (when loss is to subject matter of contract, remedy is contractual)
Tony & Susan Alamo Found. v. Sec’y of Labor, 471 U.S. 290 (U.S. 1985) (distinguishing when nonprofit activities may have a business purpose)
Coghlan v. Wellcraft Marine Corp., 240 F.3d 449 (5th Cir. 2001) (unjust enrichment unavailable where valid express contract governs)