At-will employment by state

Not recognized. Alabama courts have refused to recognize a public policy exception to at-will employment. (McClendon v. Liberty National Life Ins. Co., No. 3:11-cv-1018-WKW (M.D. Ala. Nov. 4,...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Recognized. Under Hoffman-La Roche v. Campbell, the language of an employee handbook can create a binding unilateral contract that modifies at-will status, unless the handbook expressly disclaims it. (McClendon v. Liberty National Life Ins. Co., No. 3:11-cv-1018-WKW (M.D. Ala. 2013),...; U.S. District Court, N.D. Ala., No. 2:12-cv-03493, citing Hoffman-La Roche, Inc. v....)

Pending verification. Official source (govinfo.gov).

Pending verification. Official source (labor.alaska.gov).

Pending verification. Official source (labor.alaska.gov).

Recognized. Alaska recognizes a covenant of good faith and fair dealing implied in employment contracts. (U.S. District Court for the District of Alaska, Dunlap v. Imaging Associates, No....; U.S. Court of Appeals for the Ninth Circuit, memorandum No. 19-36103 (Dec. 9, 2020),...)

Limited. Arizona's Employment Protection Act replaced the common-law Wagenseller rule: a fired employee has a wrongful termination claim only in the circumstances the statute lists, such as discharge in violation of a state statute or in retaliation for refusing to break the law or for reporting violations. (A.R.S. § 23-1501(A)(3); Noriega v. State of Arizona, No. CV-16-01015-PHX-JJT (D. Ariz. June 22, 2016), citing...)

Limited. In Arizona employment is severable at will unless there is a written contract; a handbook or manual can create such a contract only if it expresses the intent that it is a contract of employment. (A.R.S. § 23-1501(A)(2); Noriega v. State of Arizona, No. CV-16-01015-PHX-JJT (D. Ariz. June 22, 2016),...)

Pending verification. Official source (azleg.gov).

Recognized. Arkansas recognizes a limited public policy exception (Sterling Drug v. Oxford): an at-will employee may sue for wrongful discharge if fired in violation of a well-established public policy of the state; it does not protect merely private interests. (Dixon v. Arkansas Surgical Hospital, No. 4:07-cv-00084-GTE (E.D. Ark. Mar. 25, 2008),...; Harper v. Brookshire's Grocery, No. 1:03-cv-01170-HFB (W.D. Ark. Sept. 9, 2005))

Recognized. In Arkansas, the at-will doctrine does not apply when an employment agreement or personnel manual provides that the employee may not be fired except for cause; state law may provide a remedy when an employee relied on such a written promise and was fired arbitrarily. (Richardson v. City of Blytheville, No. 2:16-cv-00106-JLH (E.D. Ark. Dec. 7, 2017),...; Arkansas Department of Labor and Licensing, FAQs)

Not recognized. Arkansas courts do not recognize a wrongful discharge claim for breach of an implied covenant of good faith and fair dealing in at-will employment. (Harper v. Brookshire's Grocery, No. 1:03-cv-01170-HFB (W.D. Ark. 2005), citing Gladden...; Posluns v. Education Management Corp., No. 4:10-cv-01294 (E.D. Ark.), citing Smith v....)

Recognized. California recognizes a tort claim for wrongful termination in violation of public policy (Tameny v. Atlantic Richfield Co.), an exception to the at-will rule of the Labor Code. (Order, No. 4:13-cv-02835-DMR (N.D. Cal. July 18, 2014), citing Tameny v. Atl....; Order, No. 5:15-cv-05457 (N.D. Cal.), quoting Freund v. Nycomed Amersham, 347 F.3d...)

Recognized. California's statutory at-will presumption can be overcome by an agreement, express or implied in fact, that the employee will be fired only for good cause; courts look at the totality of circumstances, including personnel policies, length of service, employer assurances and industry practice (Foley; Guz v. Bechtel). (Order, No. 3:19-cv-04397 (N.D. Cal.), citing Guz v. Bechtel Nat. Inc., 24 Cal. 4th...; Order, No. 2:15-cv-01922-KJM-CKD (E.D. Cal. Sept. 19, 2017), quoting Guz, 24 Cal. 4th...)

Limited. In California the implied covenant of good faith and fair dealing prevents bad-faith conduct that frustrates the contract’s actual benefits; it might be violated if firing an at-will employee was a mere pretext to cheat the worker out of another contract benefit to which the employee was clearly entitled, such as compensation already earned (Guz v. Bechtel). (Order, No. 4:13-cv-02835-DMR (N.D. Cal. July 18, 2014), quoting Guz v. Bechtel Nat....; Judicial Council of California, Invitation to Comment CACI19-03 (civil jury...)

Recognized. Colorado recognizes a tort claim for wrongful discharge in violation of public policy (Martin Marietta Corp. v. Lorenz): a fired employee has a claim if the discharge contravenes a clear mandate of public policy. (Colorado Pattern Civil Jury Instructions, Chapter 31 (Wrongful Discharge), Instruction...; Order, No. 1:15-cv-02418 (D. Colo.), discussing Martin Marietta Corp. v. Lorenz, 823...)

Recognized. Colorado recognizes an implied-contract exception: termination policies in a handbook or manual can bind the employer if they were an offer the employee accepted by starting or continuing work (Continental Air Lines v. Keenan); a clear and conspicuous disclaimer defeats the claim. (Colorado Pattern Civil Jury Instructions, Chapter 31, Instruction 31:4, Notes on Use,...; Order, No. 1:19-cv-00694-WJM (D. Colo. Sept. 28, 2020), citing Cont'l Air Lines v....)

Not recognized. Colorado does not allow a tort claim for breach of the covenant of good faith and fair dealing in an employment contract (Decker v. Browning-Ferris); the public-policy wrongful discharge tort serves that role. (Colorado Pattern Civil Jury Instructions, Chapter 31, Notes on Use, citing Decker v....; Order, No. 1:15-cv-02418 (D. Colo.), discussing Decker v. Browning-Ferris Industries...)

Recognized. Connecticut recognizes a common-law claim for wrongful discharge when an at-will employee is fired in violation of an important public policy (Sheets v. Teddy's Frosted Foods). Courts treat the exception as narrow, and it is generally unavailable where a statute already provides a remedy. (Connecticut Civil Jury Instructions 3.14-3 Wrongful Discharge (citing Thibodeau v....; Dunn v. Northeast Helicopters Flight Services, LLC, 346 Conn. 360 (2023); Sheets v....)

Recognized. Connecticut recognizes that statements in an employer's personnel manual or handbook can, in appropriate circumstances, create an express or implied contract that limits at-will termination; clear disclaimers can prevent this. (Wood v. Sempra Energy Trading Corp. (D. Conn. 2005), applying Finley v. Aetna Life &...; Gallo v. Eaton Corp. (D. Conn. 2000), quoting Gaudio v. Griffin Health Services Corp.,...)

Limited. Connecticut does not let an at-will employee challenge a dismissal under the implied covenant of good faith and fair dealing unless the discharge also violates an important public policy. (Honeck (D. Conn. 2005), quoting Carbone v. Atlantic Richfield Co., 204 Conn. 460...; Zweig v. Marvelwood School, 203 Conn. App. 818 (2021), discussing Magnan v. Anaconda...)

Recognized. Delaware recognizes a claim when an at-will employee's termination violates public policy, but it is handled as one of the four exclusive categories of the implied covenant of good faith and fair dealing (E.I. duPont de Nemours & Co. v. Pressman), and applies only where no other remedial scheme exists. (Pratt v. M&T Bank Corp., No. 14-cv-1126 (D. Del.), citing Bailey v. City of...; U.S. District Court, D. Del., No. 00-803 (Brooks v. Nationwide), citing Lord v....)

Not recognized. Delaware courts hold that an employee handbook that is a unilateral statement of company policies does not create an employment contract; a contract limiting at-will termination must expressly create a definite term or otherwise expressly bar at-will termination. (U.S. District Court, D. Del., No. 00-803 (Brooks v. Nationwide), citing Heideck v....; Del. P.J.I. Civ. § 19.25 Employment Contracts - Generally (2025))

Limited. Delaware reads an implied covenant of good faith and fair dealing into at-will employment, but strictly limits it to four exclusive categories: public policy violations, employer misrepresentations relied on by the employee, using superior bargaining power to deprive the employee of earned compensation, and falsified or manipulated records used to create fictitious grounds for termination (Pressman). (U.S. District Court, D. Del., No. 00-803 (Brooks v. Nationwide), citing Lord v....; U.S. District Court, D. Del., No. 01-819, citing Pressman)

Limited. The District of Columbia recognizes a very narrow public policy exception to at-will employment (Adams v. George W. Cochran & Co.): an at-will employee may sue for wrongful discharge when the sole reason for the firing was refusing to violate a statute or municipal regulation; Carl v. Children's Hospital allows further exceptions solidly based on a statute or regulation. (Order, No. 1:15-cv-01700 (D.D.C.), quoting Adams v. George W. Cochran & Co., 597 A.2d...; Memorandum Opinion, No. 1:23-cv-02249-ABJ (D.D.C. Mar. 28, 2024), discussing Adams,...)

Recognized. In D.C., an employee handbook or personnel manual can create an implied contract that overrides at-will status, for example when it states specific preconditions that must be met before termination (Strass v. Kaiser); a clear disclaimer generally preserves at-will status. (Memorandum Opinion, No. 1:10-cv-00900-JDB (D.D.C. Dec. 21, 2010), citing Washington...; Memorandum Opinion, No. 1:17-cv-01453 (D.D.C.), quoting Strass v. Kaiser Found. Health...)

Pending verification. Official source (govinfo.gov).

Not recognized. Florida does not recognize a common-law public policy exception to at-will employment (no common-law tort for retaliatory discharge). (Order, No. 0:14-cv-61415 (S.D. Fla.), quoting Wiggins v. Southern Management Corp.,...; U.S. Bureau of Labor Statistics, Monthly Labor Review, January 2001, C. J. Muhl, "The...)

Pending verification. Official source (bls.gov).

Pending verification. Official source (bls.gov).

Pending verification. Official source (media.ca11.uscourts.gov).

Pending verification. Official source (media.ca11.uscourts.gov).

Pending verification. Official source (media.ca11.uscourts.gov).

Recognized. Hawaii recognizes a common-law claim for at-will employees fired in violation of a clear mandate of public policy (a Parnar claim, from Parnar v. Americana Hotels). (Order, No. 1:11-cv-00326 (D. Haw.), citing Parnar v. Americana Hotels, Inc., 652 P.2d...; Chan v. Wells Fargo, No. 1:14-cv-00344 (D. Haw.), citing Parnar v. Americana Hotels,...)

Recognized. In Hawaii the employer's right to fire at will can be contractually modified by statements in employee policy manuals or handbooks (Kinoshita v. Canadian Pacific Airlines). (Du Preez v. Banis, No. 1:14-cv-00171-LEK (D. Haw. Sept. 30, 2015), quoting Shoppe v....; Order, No. 1:14-cv-00155-LEK-KJM (D. Haw. Jan. 29, 2016), quoting Shoppe v. Gucci Am.,...)

Pending verification. Official source (govinfo.gov).

Recognized. Idaho recognizes a public policy exception to at-will employment: an employer may be liable when its motivation for firing an at-will employee contravenes public policy. (Davis v. George and Jesse's Les Schwab Tire Store, Inc. (Idaho Sup. Ct., Docket No....; Kreb v. Life Flight Network, LLC, No. 3:16-cv-00444-REB (D. Idaho, Memorandum Decision...)

Recognized. Idaho treats an employee as at will unless hired under a contract that specifies the duration of employment or limits the reasons for discharge; the Idaho Supreme Court refers to an express or implied agreement limiting at-will employment. (Davis v. George and Jesse's Les Schwab Tire Store, Inc. (Idaho Sup. Ct., Docket No....; U.S. District Court, D. Idaho, No. 1:12-cv-00057, citing Bollinger v. Fall River Rural...)

Pending verification. Official source (api.isc.idaho.gov).

Recognized. Illinois recognizes the tort of retaliatory discharge: an employer may fire an at-will employee for any reason or no reason, except when the discharge violates a clearly mandated public policy (Kelsay v. Motorola; Palmateer v. International Harvester). The Illinois Supreme Court describes the tort as limited and narrow. (Turner v. Memorial Medical Center, 233 Ill. 2d 494 (2009) (Ill. Sup. Ct. Docket No....; Illinois Pattern Jury Instructions (Civil), 250.00 Retaliatory Discharge, Comments)

Recognized. Illinois recognizes that an employee handbook or other policy statement can create enforceable contractual rights that limit at-will employment when the traditional requirements for contract formation are met (Duldulao v. Saint Mary of Nazareth Hospital Center). (Ross v. May Co. (Ill. App. Ct., 1st Dist., No. 1-06-0239, 2007), quoting Duldulao v....; Unterschuetz v. City of Chicago (Ill. App. Ct., 1st Dist., No. 1-02-2871), discussing...)

Pending verification. Official source (labor.illinois.gov).

Limited. Indiana's public policy exception is narrow: an employee fired for exercising a statutory right or for refusing to commit an illegal act for which the employee would be personally liable (McClanahan) has a wrongful discharge claim. It is one of three exceptions the Indiana Supreme Court recognizes (Orr); the other two are adequate independent consideration given in return for permanent employment, and promissory estoppel. (Farr v. St. Francis Hospital & Health Centers, No. 1:06-cv-00779-SEB-JMS (S.D. Ind....; Slinger v. Federal Express Corp., No. 1:11-cv-01482-JMS-MJD (S.D. Ind. Mar. 11, 2013),...)

Pending verification. Official source (govinfo.gov).

Not recognized. Indiana does not recognize a duty of good faith and fair dealing owed by an employer to an at-will employee. (Farr v. St. Francis Hospital & Health Centers, No. 1:06-cv-00779-SEB-JMS (S.D. Ind....; Farr v. St. Francis Hospital & Health Centers, No. 08-3203 (7th Cir. June 29, 2009)...)

Recognized. Iowa recognizes a narrow tort for wrongful discharge in violation of a clearly defined public policy, covering discharge for enforcing a statutory right, refusing to participate in illegal activity, or reporting workplace illegalities. (Carver-Kimm v. Reynolds (Iowa Supreme Court, June 23, 2023), citing Jasper v. H....; Ackerman v. State of Iowa (Iowa Supreme Court, June 15, 2018), citing Berry v. Liberty...)

Pending verification. Official source (dial.iowa.gov).

Not recognized. Iowa courts have not recognized a claim for breach of an implied covenant of good faith and fair dealing in employment. (Nemickas v. Linn County Anesthesiologists, P.C., No. 16-1493 (Iowa Ct. App. May 16,...; Mastin v. Navistar, Inc., No. 21-1947 (8th Cir. Jan. 14, 2022) (unpublished), quoting...)

Recognized. Kansas recognizes common-law retaliatory discharge claims as a public policy exception to at-will employment, including retaliatory discharge for whistleblowing; the claim is unavailable where an adequate alternative statutory remedy exists. (Debus v. Burlington Northern & Santa Fe Railway Co., No. 2:15-cv-09121-JAR (D. Kan....; Howard v. Millard Refrigerated Services, Inc., No. 2:04-cv-02601-JAR (D. Kan. Feb. 22,...)

Recognized. Kansas recognizes that an employer can create an implied-in-fact contract limiting at-will termination through representations in an employment manual or other sources (Morriss v. Coleman Co.); the question is the parties' intent, judged from all the circumstances. (Taylor v. Home Depot USA, Inc., No. 6:05-cv-01300-WEB (D. Kan. Mar. 20, 2007), citing...; Debus v. Burlington Northern & Santa Fe Railway Co., No. 2:15-cv-09121-JAR (D. Kan....)

Pending verification. Official source (govinfo.gov).

Recognized. Kentucky recognizes a narrow common-law claim for wrongful discharge in violation of public policy (Firestone Textile v. Meadows; Grzyb v. Evans): the discharge must be contrary to a fundamental, well-defined public policy evidenced by a constitutional or statutory provision, which the court decides as a question of law. (Lewis-Smith v. Western Kentucky University, No. 1:12-cv-00014-JHM (W.D. Ky. Jan. 9,...; Curtis v. Breathitt County Fiscal Court, No. 5:16-cv-00463-DCR (E.D. Ky. Jan. 22,...)

Recognized. In Kentucky, at-will employment can be changed to a for-cause relationship, for example through an employer's policies and procedures, when the parties clearly state that intent (Shah v. American Synthetic Rubber). (Curtis v. Breathitt County Fiscal Court, No. 5:16-cv-00463-DCR (E.D. Ky. Jan. 22,...; Wells v. Huish Detergents, Inc., No. 1:98CV-131-R (W.D. Ky.), citing Shah v. American...)

Pending verification. Official source (kywd.uscourts.gov).

Not recognized. Louisiana does not recognize a common-law public-policy exception to at-will employment; under the Civil Code an employer may dismiss an at-will employee for any reason, provided the termination does not violate a statutory or constitutional provision (such as anti-discrimination laws). (U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...; Narcisse v. Turner Indus. Group, No. 11-2659 (E.D. La. Apr. 30, 2012), citing La. Civ....)

Pending verification. Official source (bls.gov).

Pending verification. Official source (bls.gov).

Pending verification. Official source (govinfo.gov).

Limited. Maine enforces a promise that employment may be ended only for cause only if the restriction on the employer’s right to terminate is clearly stated; employee manuals whose restrictions are not clearly stated are not contracts (Larrabee v. Penobscot Frozen Foods). (Fitzpatrick v. Teleflex, No. 1:08-cv-400 (D. Me.), citing Larrabee v. Penobscot Frozen...; Caudill v. Kennebec County, No. 1:18-cv-00164 (D. Me. Mar. 19, 2019), citing Barrera...)

Pending verification. Official source (govinfo.gov).

Recognized. Maryland recognizes a tort of wrongful ("abusive") discharge when the motivation for firing an at-will employee contravenes a clear mandate of public policy (Adler v. American Standard Corp.); courts treat it as a narrow exception. (Parks v. Alpharma, Inc., 421 Md. 59 (2011) (Md. Court of Appeals, No. 115, Sept. Term...; Holden v. University System of Maryland, No. 0369, Sept. Term 2014 (Md. Ct. Spec....)

Recognized. In Maryland, personnel-policy or handbook provisions that limit the employer’s discretion to terminate, or set a required termination procedure, may become enforceable contractual undertakings if properly expressed and communicated (Staggs v. Blue Cross of Maryland); an express disclaimer of contractual intent defeats the claim. (Spacesaver Systems, Inc. v. Adam, No. 1797, Sept. Term 2011 (Md. Ct. Spec. App.,...; Bagwell v. Peninsula Regional Medical Center, 106 Md. App. 470 (1995) (Md. Ct. Spec....)

Not recognized. Maryland does not recognize a separate cause of action for breach of the implied covenant of good faith and fair dealing; such allegations are pursued, if at all, as part of a breach-of-contract claim. (Magnetti v. University of Maryland, No. 2492, Sept. Term 2005 (Md. Ct. Spec. App....; U.S. District Court, D. Md., No. 1:14-cv-00676, citing Ward v. 84 Lumber, 758 F. Supp....)

Recognized. Massachusetts recognizes a wrongful-termination claim for at-will employees only when the firing violates a clearly established public policy (King v. Driscoll); the Supreme Judicial Court interprets this exception narrowly. (Dineen v. Dartmouth-Hitchcock Medical Center, No. 1:13-cv-12200 (D. Mass. Feb. 3,...; Suzuki v. Abiomed, Inc., No. 19-1233 (1st Cir.), n.4, citing King v. Driscoll, 638...)

Recognized. In Massachusetts, employment is presumed to be at will unless an express or implied contract governs its terms and conditions. (Dineen v. Dartmouth-Hitchcock Medical Center, No. 1:13-cv-12200 (D. Mass. 2014), n.2,...; Day v. Staples, Inc., 555 F.3d 42 (1st Cir. 2009), No. 08-1689)

Limited. Massachusetts implies a covenant of good faith and fair dealing in at-will employment contracts, but it is limited: an employer who fires an employee in bad faith is liable for unpaid compensation clearly connected to work already performed (Fortune v. National Cash Register). (Bradley v. Cruz, No. 1:13-cv-12927 (D. Mass. Nov. 3, 2014), quoting Harrison v....; Suzuki v. Abiomed, Inc., No. 19-1233 (1st Cir.), quoting Ayash v. Dana-Farber Cancer...)

Limited. Michigan recognizes limited public policy exceptions (Suchodolski v. Michigan Consolidated Gas): an employee fired for refusing to violate a law, performing a legal duty, or exercising a legal right can sue; no such claim lies where a statute already prohibits the retaliation and provides a remedy. (Order, No. 1:04-cv-00835 (W.D. Mich. Aug. 8, 2006), citing Suchodolski v. Mich....; Order, No. 1:04-cv-00836 (W.D. Mich.), citing Suchodolski v. Mich. Consol. Gas Co.,...)

Recognized. Michigan's at-will presumption can be rebutted: stated employer policies and established procedures can make a right to continued employment absent just cause enforceable in contract or through a legitimate-expectations claim (Toussaint v. Blue Cross & Blue Shield). (Kinch v. Pinnacle Foods Group LLC, No. 2:16-cv-12840 (E.D. Mich. July 17, 2017),...; Order, No. 3:22-cv-10449-RHC (E.D. Mich. Dec. 8, 2022), quoting Lytle v. Malady, 458...)

Pending verification. Official source (govinfo.gov).

Limited. Minnesota's common-law public policy claim is narrow (Phipps v. Clark Oil): an employee fired for refusing to participate in an activity the employee in good faith believes violates a state or federal law, rule or regulation may sue; the Supreme Court has declined to recognize a broader claim for any violation of public policy. (Wredberg v. Canvas Health, Inc., No. A24-1897 (Minn. Aug. 12, 2026), citing Phipps v....; Dukowitz v. Hannon Security Services, 841 N.W.2d 147 (Minn. 2014), No. A11-1481)

Recognized. In Minnesota, employee handbook provisions can be enforceable as a unilateral employment contract, even when employment is for an indefinite duration. (Hall v. City of Plainview, No. A19-0606 (Minn. Feb. 3, 2021), syllabus, applying Pine...; Hovind v. Bristol Place Corp., No. 08-597 (D. Minn. Oct. 24, 2008), quoting Pine River...)

Not recognized. Minnesota courts have declined to read an implied covenant of good faith and fair dealing into employment contracts. (Mandel v. Multiband Corp., No. A15-1133 (Minn. Ct. App. Mar. 28, 2016) (unpublished),...; Good v. Ameriprise Financial, Inc., No. 06-CV-1027 (D. Minn. Jan. 18, 2008), citing...)

Limited. Mississippi's public policy exception to at-will employment is narrow (McArn v. Allied Bruce-Terminix): an employee may sue in tort if fired for refusing to participate in an illegal act or for reporting the employer's illegal acts. (McArn v. Allied Bruce-Terminix Co., 626 So. 2d 603, 607 (Miss. 1993), as stated in...; McArn v. Allied Bruce-Terminix Co., 626 So. 2d 603, 607 (Miss. 1993), as stated in...)

Recognized. Mississippi courts have recognized that even at-will employees may have contractual rights based on provisions in the employer's employee manual (Bobbitt v. The Orchard), unless the manual reserves the employer's right to terminate at will. (Bobbitt v. The Orchard, Ltd., 603 So. 2d 356, 361 (Miss. 1992), as stated in Nuwer v....; U.S. Court of Appeals for the Fifth Circuit, No. 13-60088 (Jan. 16, 2014), discussing...)

Pending verification. Official source (ca5.uscourts.gov).

Recognized. Missouri recognizes a public-policy exception to at-will employment (Fleshner v. Pepose Vision Institute): an at-will employee may not be fired for refusing to violate the law or a clear mandate of public policy, or for reporting wrongdoing. The Whistleblower's Protection Act codifies the existing common-law exceptions, limits their future expansion by the courts and, together with chapters 213 and 287, provides the exclusive remedy for claims of unlawful employment practices. (Mo. Rev. Stat. § 285.575.3 (Whistleblower's Protection Act, L. 2017 S.B. 43); Fleshner v. Pepose Vision Institute, P.C., 304 S.W.3d 81 (Mo. 2010) (en banc), as...)

Pending verification. Official source (documents.house.mo.gov).

Pending verification. Official source (documents.house.mo.gov).

Pending verification. Official source (leg.mt.gov).

Pending verification. Official source (leg.mt.gov).

Pending verification. Official source (leg.mt.gov).

Statutory wrongful discharge: Recognized. Montana's Wrongful Discharge from Employment Act replaces at-will employment once the probationary period ends: after the employee has completed the employer's probationary period, a discharge that is not for good cause is wrongful. The Act is the exclusive remedy for wrongful discharge and common-law tort and contract claims for discharge are preempted. (Mont. Code Ann. § 39-2-904(1)(b) (Wrongful Discharge from Employment Act); Montana Department of Labor & Industry, Employee Handbook: Sample Policies (Rev. 2/2016))

Recognized. Nebraska recognizes a public policy exception to at-will employment: an employee may claim damages for wrongful discharge when the motivation for the firing contravenes public policy. The Nebraska Supreme Court describes it as limited to cases where a clear mandate of public policy has been violated. (Dibbern v. York Surgical Assocs., 318 Neb. 928 (2025); Trosper v. Bag 'N Save, 734 N.W.2d 704 (Neb. 2007), as stated in Teetor v. Dawson...)

Pending verification. Official source (nebraska.gov).

Pending verification. Official source (nebraska.gov).

Pending verification. Official source (cdn.ca9.uscourts.gov).

Pending verification. Official source (cdn.ca9.uscourts.gov).

Pending verification. Official source (cdn.ca9.uscourts.gov).

Recognized. New Hampshire recognizes a common-law wrongful termination claim when the employer fired the employee out of bad faith, malice, or retaliation, and did so because the employee performed acts public policy would encourage or refused to perform acts public policy would condemn (Cloutier; Short v. School Administrative Unit). (Faulkner v. Dartmouth-Hitchcock Medical Center, No. 1:12-cv-00482-SM (D.N.H. Aug. 12,...; McMillen v. Concord Hospital, No. 1:12-cv-00077-SM (D.N.H. Sept. 22, 2014), quoting...)

Recognized. New Hampshire recognizes that an employee handbook can function as a contract that alters at-will employment (Panto v. Moore Business Forms). (Balsamo v. University System of New Hampshire, No. 1:10-cv-00500-PB, 2011 DNH 150...; Butler v. Hitchiner Manufacturing Corp., No. CV-96-624-JD (D.N.H. Dec. 4, 1997),...)

Pending verification. Official source (govinfo.gov).

Recognized. New Jersey recognizes a wrongful-discharge claim when firing an at-will employee is contrary to a clear mandate of public policy (Pierce v. Ortho Pharmaceutical Corp.). (Pierce v. Ortho Pharmaceutical Corp., 84 N.J. 58, 417 A.2d 505 (1980), as applied in...; Pierce v. Ortho Pharmaceutical Corp., 84 N.J. 58 (1980), as applied in D.N.J. No....)

Recognized. Under Woolley v. Hoffmann-La Roche, absent a clear and prominent disclaimer, a promise in an employment manual that an employee will be fired only for cause may be enforceable even though the employment would otherwise be at will. (Woolley v. Hoffmann-La Roche, Inc., 99 N.J. 284, 491 A.2d 1257 (1985), as quoted in...; Woolley v. Hoffmann-La Roche, Inc., 99 N.J. 284 (1985), as quoted in D.N.J. No....)

Limited. New Jersey courts do not allow a stand-alone claim for breach of the implied covenant of good faith and fair dealing by an at-will employee: the claim requires an underlying contract (for example an express contract or a Woolley handbook contract). (D.N.J. No. 2:05-cv-01880 (citing Schlichtig v. Inacom Corp., 271 F. Supp. 2d 597...; D.N.J. No. 1:15-cv-06284 (citing Noye v. Hoffmann-La Roche Inc., 238 N.J. Super. 430...)

Recognized. New Mexico recognizes a retaliatory (wrongful) discharge tort: an at-will employee may recover when the discharge contravenes a clear mandate of public policy (first recognized in Vigil v. Arzola). (Herndon v. Best Buy (10th Cir.), quoting Chavez v. Manville Prods. Corp., 108 N.M....; D.N.M. No. 1:16-cv-01144, citing Vigil v. Arzola, 102 N.M. 682, 699 P.2d 613 (Ct. App....)

Recognized. In New Mexico, a representation in an employee handbook or personnel policies can create an implied contract that limits the employer's right to fire at will, if it is definite enough to create a reasonable expectation (Hartbarger v. Frank Paxton Co.). (D.N.M. No. 1:05-cv-00461, quoting Trujillo v. Northern Rio Arriba Elec. Coop., 131...; D.N.M. No. 1:16-cv-01144, citing Trujillo v. N. Rio Arriba Elec. Coop., Inc.,...)

Not recognized. New Mexico does not recognize a claim for breach of the implied covenant of good faith and fair dealing in an at-will employment relationship (Melnick v. State Farm). (D.N.M. No. 1:12-cv-00261 (Back v. ConocoPhillips), quoting Melnick v. State Farm Mut....; D.N.M. No. 1:11-cv-00109, citing Melnick v. State Farm Mut. Auto. Ins. Co., 106 N.M....)

Not recognized. New York does not recognize a common-law claim for wrongful or retaliatory discharge of an at-will employee in violation of public policy; the Court of Appeals has left any such claim to the legislature. (Metellus v. JetBlue, No. 2:07-cv-04719 (E.D.N.Y. Mar. 30, 2010), citing Horn v. N.Y....; U.S. District Court, E.D.N.Y., No. 2:09-cv-03135, quoting Barcellos v. Robbins, 858...)

Limited. At-will status can be overcome only by an express written limitation on the employer's right to terminate (Weiner v. McGraw-Hill); vague oral assurances or the mere existence of a written policy are not enough. (U.S. District Court, N.D.N.Y., No. 5:02-cv-01112 (Mar. 31, 2006), citing Weiner v....; Metellus v. JetBlue, No. 2:07-cv-04719 (E.D.N.Y. Mar. 30, 2010), quoting De Petris v....)

Not recognized. New York does not imply a covenant of good faith and fair dealing that limits an employer's right to terminate an at-will employee (Murphy v. American Home Products; Sabetay v. Sterling Drug). (Nornberg v. Thai Magic Co., 2006 NY Slip Op 50104(U) (Sup. Ct. N.Y. County), quoting...; U.S. District Court, N.D. Ala., No. 2:12-cv-00205 (Apr. 19, 2012), applying New York...)

Recognized. North Carolina recognizes a common-law claim for wrongful discharge in violation of public policy: an employer may not fire an at-will employee for an unlawful reason or purpose that contravenes a specific expression of state public policy, such as a statute or regulation (Coman v. Thomas Mfg.; Amos v. Oakdale Knitting). (Shook v. NCG Acquisition, No. 23-1406 (4th Cir. 2024) (published), quoting Coman v....; U.S. District Court, W.D.N.C., No. 5:24-cv-00192 (Sept. 3, 2025), citing Amos v....)

Limited. Employee handbooks and policies an employer issues on its own do not become part of the employment contract unless they are expressly included in it (Walker v. Westinghouse), so they rarely change at-will status. (U.S. District Court, M.D.N.C., No. 1:12-cv-00286, citing Walker v. Westinghouse Elec....; U.S. District Court, M.D.N.C., No. 1:24-cv-450 (memorandum opinion))

Not recognized. North Carolina does not recognize a wrongful discharge claim by an at-will employee based on an implied covenant of good faith and fair dealing. (U.S. District Court, M.D.N.C., No. 1:24-cv-00323, quoting Hardin v. Belmont Textile...; Patterson v. City of Graham, No. 1:24-cv-00399 (M.D.N.C. Sept. 15, 2025), citing...)

Pending verification. Official source (nd.gov).

Pending verification. Official source (nd.gov).

Pending verification. Official source (nd.gov).

Recognized. Ohio recognizes a claim for wrongful discharge in violation of public policy (Greeley v. Miami Valley Maintenance; Painter v. Graley) when an at-will employee is fired in contravention of a clear public policy found in the Ohio or U.S. Constitution, statutes, administrative rules or the common law. (U.S. District Court, S.D. Ohio, No. 1:20-cv-00813 (Apr. 26, 2021), quoting Dohme v....; U.S. District Court, N.D. Ohio, No. 3:18-cv-00538, citing Greeley v. Miami Valley...)

Recognized. Ohio recognizes two contract-based exceptions to at-will employment (Mers v. Dispatch Printing): an implied contract arising from a handbook, company policy or oral representations, and promissory estoppel based on the employer's promises. (U.S. District Court, N.D. Ohio, No. 3:11-cv-00236, citing Tersigni v. Gen. Tire, Inc.,...; U.S. District Court, N.D. Ohio, No. 3:07-cv-01084, citing McIntosh v. Roadway Express,...)

Not recognized. Although every Ohio contract carries a covenant of good faith and fair dealing, there is no separate cause of action for breach of a duty of good faith in the at-will employment context. (U.S. District Court, S.D. Ohio, No. 2:15-cv-02223, quoting Padula v. Wagner,...; Schoenberg v. Fifth Third Bank, No. 1:07-cv-00276 (S.D. Ohio), quoting Borowski v....)

Recognized. Oklahoma recognizes a narrow tort (the Burk tort, from Burk v. K-Mart Corp.) for an at-will employee fired for refusing to violate, or for acting consistently with, a clear and compelling public policy articulated in Oklahoma constitutional, statutory or decisional law. (U.S. Court of Appeals, 10th Cir., No. 06-5205, citing Burk v. K-Mart Corp., 770 P.2d...; McKenzie v. Renberg's Inc., No. 94-5197 (10th Cir.) (published), discussing Burk v....)

Recognized. Oklahoma recognizes implied employment contracts, including ones based on handbooks and policy manuals (Hinson v. Cameron; Hayes v. Eateries); courts balance factors such as separate consideration, length of employment, handbooks, detrimental reliance and promotions, and vague assurances are not enough. (Wood v. Handy & Harman Co., No. 06-5226 (10th Cir. Aug. 1, 2008) (unpublished),...; U.S. District Court, W.D. Okla., No. 5:16-cv-00817, citing Hayes v. Eateries, Inc.,...)

Not recognized. Oklahoma does not imply a covenant of good faith and fair dealing in at-will employment (Burk v. K-Mart Corp.), so an at-will employee cannot sue for a bad-faith termination. (Langston v. Therma-Tru Corp., No. 6:07-cv-00250 (E.D. Okla. Jan. 18, 2008), citing...; Merrick v. Northern Natural Gas, No. 89-5012 (10th Cir.), discussing Burk v. K-Mart...)

Recognized. Oregon recognizes the common-law tort of wrongful discharge as a narrow exception to at-will employment, in two situations: discharge for performing a public duty or fulfilling a societal obligation (for example jury duty, Nees v. Hocks), and discharge for exercising an important job-related right. (U.S. District Court, D. Or., No. 3:06-cv-01012 (Dec. 3, 2007), citing Sheets v....; U.S. District Court, D. Or., No. 3:07-cv-01002, citing Sheets v. Knight, 779 P.2d...)

Recognized. Statements in an employee handbook can become part of the employment contract (Yartzoff v. Democrat-Herald), but a clear disclaimer in the handbook or personnel policies keeps the employee at will. (U.S. District Court, D. Or., No. 3:23-cv-00136, citing Yartzoff v. Democrat-Herald...; U.S. District Court, D. Or., No. 3:16-cv-02072, quoting Yartzoff v. The...)

Not recognized. The Oregon Supreme Court (Sheets v. Knight) declined to apply the duty of good faith and fair dealing to an employer's right to discharge an at-will employee. (U.S. District Court, D. Or., No. 6:04-cv-06326 (Oct. 5, 2005), quoting Sheets v....; O'Donnell v. Ameresco, Inc., No. 3:23-cv-00085 (D. Or.), citing Sheets v. Knight, 308...)

Limited. Pennsylvania recognizes a very narrow public policy exception to at-will employment: the firing must violate a clear public policy found in the constitution, legislation, a regulation or a judicial decision, and courts have applied it mainly where the employer required a crime, prevented compliance with a statutory duty, or fired the employee where a statute specifically prohibits it. (Tanay v. Encore Healthcare, LLC, No. 2:10-cv-00792 (E.D. Pa. Aug. 26, 2011), citing...; Donaldson v. Informatica Corp., No. 2:09-cv-00804 (W.D. Pa. May 31, 2011))

Limited. Pennsylvania strongly presumes at-will employment; the presumption is overcome only by an express contract, an implied agreement supported by additional consideration, or clear and precise evidence of a contract for a definite term. Vague assurances or subjective expectations are not enough. (McGee v. Procter & Gamble Distributing Co., No. 2:02-cv-01121 (E.D. Pa. Aug. 3, 2006),...; Hardee-Guerra v. Shire Pharmaceuticals, No. 2:09-cv-01547 (E.D. Pa. Aug. 25, 2010),...)

Not recognized. An at-will employee in Pennsylvania cannot sue for breach of the implied duty of good faith and fair dealing over the termination itself (Donahue v. Federal Express). (McGee v. Procter & Gamble Distributing Co., No. 2:02-cv-01121 (E.D. Pa. Aug. 3, 2006),...; Hardee-Guerra v. Shire Pharmaceuticals, No. 2:09-cv-01547 (E.D. Pa. Aug. 25, 2010))

Not recognized. Rhode Island courts do not recognize a common-law claim for wrongful discharge of an at-will employee in violation of public policy (Pacheco v. Raytheon); protections come from statutes. (Shumacher v. Fairfield Resorts, Inc., No. 1:05-cv-00500 (D.R.I. June 8, 2007), quoting...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Pending verification. Official source (bls.gov).

Not recognized. Rhode Island does not imply a covenant of good faith and fair dealing that limits termination of an at-will employee; the covenant exists only alongside a binding contract. (Bisbano v. Strine Printing Co., No. 13-1722 (1st Cir. Nov. 27, 2013), citing...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Pending verification. Official source (scstatehouse.gov).

Pending verification. Official source (scstatehouse.gov).

Pending verification. Official source (scstatehouse.gov).

Recognized. South Dakota, where employment is at will by statute, recognizes a narrow public policy exception: an employee fired in retaliation for refusing to commit a criminal or unlawful act has a wrongful discharge claim; the South Dakota labor department also lists firing for exercising a lawful right such as filing a workers' compensation claim. (U.S. District Court, D.S.D., No. 5:06-cv-05056 (Apr. 17, 2008), quoting Johnson v....; South Dakota Department of Labor & Regulation, Termination of Employment)

Limited. A contract can override at-will status in South Dakota, including an implied for-cause-only contract, but only where the employee handbook contains a detailed list of exclusive grounds for discharge and a mandatory specific procedure the employer agrees to follow. (U.S. District Court, D.S.D., No. 5:06-cv-05056 (Apr. 17, 2008), quoting Bass v. Happy...; South Dakota Department of Labor & Regulation, Termination of Employment)

Not recognized. South Dakota courts have refused to impose an implied covenant of good faith and fair dealing on employment contracts in a way that overrides the at-will statute. (U.S. District Court, D.S.D., No. 5:06-cv-05056 (Apr. 17, 2008), describing Peterson,...; Koch v. Tracy, No. 4:15-cv-04102 (D.S.D. July 12, 2016), citing Farm Credit Servs. of...)

Recognized. Tennessee recognizes a common-law retaliatory discharge claim for an at-will employee fired for trying to exercise a statutory or constitutional right, or for any other reason that violates a clear public policy evidenced by an unambiguous constitutional, statutory or regulatory provision (Webb v. Nashville Area Habitat for Humanity). A statutory claim also exists under the Tennessee Public Protection Act. (Levan v. Sears, Roebuck & Co., No. 3:11-cv-578 (E.D. Tenn. Nov. 25, 2013); Young v. United Parcel Service, Inc., No. 3:12-cv-0261 (M.D. Tenn. Jan. 16, 2014),...)

Limited. A Tennessee employee handbook can become part of an employment contract, but only if it contains specific language showing the employer's intent to be bound by its provisions (Keller v. Casteel; Rose v. Tipton County); courts apply a high standard, and language reserving the employer's right to change the handbook generally prevents it from being a contract. (Freeze v. City of Decherd, No. 12-6160 (6th Cir. June 4, 2014) (published), citing...; Bowman v. Town of Ashland City, No. 3:25-cv-00193 (M.D. Tenn. Feb. 17, 2026), quoting...)

Not recognized. In Tennessee the implied duty of good faith and fair dealing cannot modify the employment-at-will doctrine: an employer does not breach it by firing an at-will employee for any reason (Goot v. Metropolitan Government of Nashville). (Coker v. Carrier Corp., No. 4:05-cv-00051 (E.D. Tenn.), quoting Goot v. Metro. Gov't...; Foxx v. Healix Infusion Therapy, Inc., No. 3:12-cv-00120 (E.D. Tenn. Mar. 4, 2013),...)

Limited. Texas recognizes only a very narrow public-policy exception (Sabine Pilot Service, Inc. v. Hauck): an employer may not fire an employee for refusing to perform an illegal act. (Texas Workforce Commission, Texas Guidebook for Employers (2024), Outline of...; Garcia v. Sunbelt (5th Cir., No. 02-50542), discussing Sabine Pilot Service, Inc. v....)

Pending verification. Official source (efte.twc.texas.gov).

Pending verification. Official source (efte.twc.texas.gov).

Recognized. Utah recognizes a tort claim for wrongful discharge in violation of a clear and substantial public policy. (U.S. District Court, D. Utah, No. 2:03-cv-01088 (applying Utah law); Hogan v. UTOPIA (10th Cir., No. 14-4138) (applying Utah law))

Recognized. In Utah an at-will relationship may be modified by an implied-in-fact contract, which may be shown by conduct and oral statements. (U.S. District Court, D. Utah, No. 2:17-cv-00978 (applying Utah law); Zisumbo v. Ogden Regional Medical Center, No. 13-4179 (10th Cir. Sept. 4, 2015),...)

Not recognized. Utah refuses to recognize an implied covenant of good faith that would replace the at-will rule or require good cause for discharge. (U.S. District Court, D. Utah, No. 2:05-cv-00550 (applying Utah law); Zisumbo v. Ogden Regional Medical Center, No. 13-4179 (10th Cir. Sept. 4, 2015),...)

Recognized. Vermont employers may not discharge an at-will employee for a reason against which there is a clear and compelling public policy. (Marcoux-Norton v. Kmart Corp., 907 F. Supp. 766 (D. Vt. 1993), copy filed with the...; Cole v. Foxmar Inc., No. 2:18-cv-220 (D. Vt. May 16, 2019), quoting Dulude v. Fletcher...)

Pending verification. Official source (labor.vermont.gov).

Limited. In Vermont the implied covenant of good faith and fair dealing has little effect in a pure at-will employment relationship and is not recognized as a means of recovery where the relationship is unmodified and at-will. (Marcoux-Norton v. Kmart Corp., 907 F. Supp. 766 (D. Vt. 1993), copy filed with the...; Cole v. Foxmar Inc., No. 2:18-cv-220 (D. Vt. May 16, 2019), quoting Dicks v. Jensen,...)

Limited. Virginia recognizes only a narrow public-policy exception to at-will employment (Bowman v. State Bank of Keysville), which its Supreme Court has construed narrowly and applied in few instances. (Bailey v. Scott-Gallaher, Inc., Supreme Court of Virginia, Record No. 960530; Mitchem v. Counts, Supreme Court of Virginia, Record No. 990399)

Pending verification. Official source (dmas.virginia.gov).

Pending verification. Official source (dmas.virginia.gov).

Recognized. Washington recognizes the tort of wrongful discharge in violation of public policy (adopted in Thompson v. St. Regis Paper Co.) as a narrow exception to at-will employment. (Martin v. Gonzaga University, Washington Supreme Court No. 95269-8 (slip opinion); Rose v. Anderson Hay & Grain Co., Washington Supreme Court No. 90975-0)

Pending verification. Official source (lni.wa.gov).

Pending verification. Official source (lni.wa.gov).

Recognized. West Virginia recognizes a common-law claim (a Harless claim) when an employer fires an at-will employee to contravene a substantial public policy principle. (Keffer v. Fayette County Board of Education, No. 22-631 (W. Va. Oct. 25, 2024)...; Longerbeam v. Shepherd University, Nos. 22-609 and 22-610 (W. Va. Apr. 11, 2024),...)

Recognized. West Virginia presumes at-will employment, but contractual provisions on discharge or job security, including a definite promise of job security in an employee handbook, can alter at-will status (Cook v. Heck's). (Veltri v. Graybar Electric Co., No. 5:09-cv-00101 (N.D. W. Va.), quoting Pleasant v....; Coleman v. Housing Authority of the City of Weirton, No. 5:12-cv-00151 (N.D. W. Va....)

Not recognized. West Virginia does not recognize an implied covenant of good faith and fair dealing in at-will employment; an employer has no implied duty to act in good faith when discharging an at-will employee, as long as the motivation does not contravene substantial public policy. (Coleman v. Housing Authority of the City of Weirton, No. 5:12-cv-00151 (N.D. W. Va....; Lucas v. United Fabricating, Inc., No. 5:06-cv-00154 (N.D. W. Va.), describing Shell...)

Recognized. Wisconsin recognizes a narrow public policy exception (Brockmeyer v. Dun & Bradstreet): a fired employee has a wrongful discharge claim only when the discharge is contrary to a fundamental and well-defined public policy evidenced by existing constitutional, statutory or administrative law. (Robinette v. Westconsin Credit Union, No. 3:09-cv-00600 (W.D. Wis. Feb. 25, 2010),...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Limited. In Wisconsin a handbook that sets out mandatory discharge procedures can create an employment contract (Ferraro v. Koelsch), but an employee is considered at will unless evidence expressly shows the parties intended to be bound to a different arrangement. (Williams v. Milwaukee Health Services Inc., No. 13-3412 (7th Cir. Apr. 18, 2014),...; Barkow v. School District of Athens, No. 22-1521 (7th Cir. Oct. 20, 2022), citing...)

Not recognized. The Wisconsin Supreme Court (Brockmeyer v. Dun & Bradstreet) has refused to impose a duty to terminate in good faith into employment contracts. (Gilsinger v. Cities and Villages Mutual Insurance Co., No. 23-2963 (7th Cir. Aug. 9,...; Kempfer v. Automated Finishing, Inc., No. 95-0649 (Wis. June 20, 1997), quoting...)

Limited. Wyoming recognizes a limited public policy exception to at-will employment (McLean v. Hyland Enterprises): the employee must identify a strong and well-established public policy and show that no other remedy is available. (McBride v. Peak Wellness Center, Inc., No. 11-8037 (10th Cir. Aug. 6, 2012), quoting...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Recognized. Wyoming presumes employment is at will, but employers and employees can depart from that presumption through an express or implied contract, which may include an employee handbook; a handbook disclaimer can preserve at-will status. (McBride v. Peak Wellness Center, Inc., No. 11-8037 (10th Cir. Aug. 6, 2012), citing...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)

Limited. Every Wyoming employment contract contains an implied covenant of good faith and fair dealing (Wilder v. Cody Country Chamber of Commerce), but a breach is actionable in tort only where a special relationship of trust and reliance exists between employer and employee, which arises only in rare and exceptional cases. (McBride v. Peak Wellness Center, Inc., No. 11-8037 (10th Cir. Aug. 6, 2012), citing...; U.S. Bureau of Labor Statistics, Monthly Labor Review (Jan. 2001), "The...)