Wakeley v. M.J. Brunner, Inc.
147 A.3d 1
| Pa. Super. Ct. | 2016Background
- Wakeley, a Dallas-based project manager earning $80,000, was recruited by M.J. Brunner for positions in Pittsburgh in 2012; she ultimately accepted an account director offer paying $90,000 plus a $9,000 relocation allowance and moved her family to Pittsburgh.
- Brunner allegedly promised extensive training, supervision, and a permanent comparable position after an incumbent’s maternity leave; Wakeley claims she received little training or supervision and was terminated four days before the incumbent returned.
- Wakeley sued alleging breach of implied contract (additional consideration from relocation), breach of express contract (promised training/supervision/permanent position), and fraudulent inducement (knowingly false promises).
- Brunner attached two pre-hire documents signed by Wakeley: an earlier application (signed April 2, 2012) and a Confirmation of Employment signed immediately before starting, which expressly stated employment was at-will and no representative could alter that.
- The trial court granted Brunner judgment on the pleadings and dismissed Wakeley’s complaint with prejudice; the Superior Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wakeley alleged sufficient additional consideration to rebut at-will presumption | Wakeley argued relocating her family, leaving a stable job, and taking a 30-year mortgage constituted additional consideration | Brunner argued Wakeley expressly acknowledged at-will status in pre-hire documents, defeating any claim of contract duration | Held: Confirmation acknowledging at-will employment defeats additional consideration as a matter of law; claim barred |
| Whether parties entered a specific agreement other than at-will | Wakeley contended oral/promissory assurances created enforceable terms | Brunner relied on written confirmation disclaiming any contrary agreements and reserving at-will status | Held: Written confirmation controlled; no enforceable specific-term agreement existed |
| Whether Wakeley pleaded breach of express contract (training, supervisor, permanent position) | Wakeley alleged Brunner promised training, experienced supervision, and a comparable permanent position and breached those promises | Brunner argued any such promises were disclaimed by the at-will confirmation and no representative could bind the company | Held: Express-contract claim precluded by Wakeley’s signed at-will confirmation |
| Whether Wakeley adequately pleaded fraudulent inducement | Wakeley alleged Brunner knowingly made false promises to induce relocation and employment | Brunner argued no justifiable reliance where Wakeley signed an at-will confirmation disavowing contrary promises | Held: Fraud claim precluded because signed at-will confirmation negated justifiable reliance (alternative trial-court reasoning on scienter noted but appellate affirmance on other ground) |
Key Cases Cited
- Wachovia Bank, N.A. v. Ferretti, 935 A.2d 565 (Pa. Super. 2007) (standard of review for judgment on the pleadings)
- Cashdollar v. Mercy Hosp. of Pittsburgh, 595 A.2d 70 (Pa. Super. 1991) (additional consideration can rebut employment at-will presumption)
- Walden v. Saint Gobain Corp., 323 F. Supp. 2d 637 (E.D. Pa. 2004) (acknowledgment of at-will employment defeats implied-contract claims)
- Liberty Mut. Ins. Co. v. Domtar Paper Co., 77 A.3d 1282 (Pa. Super. 2013) (appellate courts may affirm on any correct ground)
- Clay v. Advanced Computer Applications, Inc., 559 A.2d 917 (Pa. 1989) (general rule: no common-law cause for termination of at-will employment)
- Martin v. Hale Prods., Inc., 699 A.2d 1283 (Pa. Super. 1997) (fraud claim requires justifiable reliance)