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Howard SMITH III v. AMERICAN GREETINGS CORPORATION, an Ohio Corporation

Supreme Court of Arkansas
Opinion delivered February 25, 1991.

1. LABOR—EMPLOYMENT-AT-WILL DOCTRINE APPLIED.—The employment-at-will doctrine provides that a contract of employment for an indefinite term is terminable at the will of either party; an at-will employee may be discharged for good cause, no cause, or even a morally wrong cause so long as it does not violate public policy.
2. MOTIONS—MOTION FOR JUDGMENT ON THE PLEADINGS—FACTS ALLEGED IN COMPLAINT TREATED AS TRUE.—In considering a motion for a judgment on the pleadings for failure to state facts upon which relief can be granted, the facts alleged in the complaint must be treated as true and viewed in the light most favorable to the party seeking relief.
3. LABOR—EXCEPTION TO THE EMPLOYMENT-AT-WILL DOCTRINE IF PURSUING MATTER IN THE PUBLIC INTEREST.—Where in a wrongful-discharge action an employee alleged the redress of a private wrong and not that he was pursuing some matter in the public interest, there was no exception to the employment-at-will doctrine, and the trial court properly ruled that the complaint did not state facts upon which relief could be granted.
4. LABOR—EMPLOYMENT AT WILL—NO CAUSE OF ACTION—NO EXPRESS PROVISION SHOWN.—A statement in an employment handbook that the employer desired to provide maximum job security for its employees was not an express provision that employees could be discharged only for cause; therefore, an at-will