Morrison v. Nana Worleyparsons, LLC

[EMPLOYMENT LAW]

In Morrison v. Nana Worleyparsons, LLC,[1] the supreme court held that short-term performance plans, without express indications to the contrary, do not alter at-will employment contracts.[2] Morrison, an at-will employee at Nana Worleyparsons, was placed onto a Performance Improvement Plan (“PIP”) aimed at improving his lackluster work performance and negative attitude.[3] Shortly thereafter, Morrison made an inappropriate comment to a co-worker at a work party and was fired.[4] On appeal, Morrison argued that Nana Worleyparsons both breached his contract and the implied covenant of good faith and fair dealing.[5]  The supreme court affirmed the lower court’s decision, reasoning that since the PIP did not contain any express indications changing the at-will nature of Morrison’s employment, the PIP did not alter his original at-will employment contract.[6] The court further reasoned Nana Worleyparson’s actions did not breach the implied covenants of good faith and fair dealing because their actions were both objectively and subjectively appropriate in Morrison’s particular circumstance.[7] Affirming the lower court’s decision, the supreme court held that short-term performance plans, without express indications to the contrary, do not alter at-will employment contracts.[8]

 



[1] 314 P.3d 508 (Alaska 2013).

[2] Id. at 510–12.

[3] Id. at 509.

[4] Id. at 510.

[5] Id.

[6] Id. at 511–12.

[7] Id.

[8] Id. at 510–12.

Morrison v. Nana Worleyparsons, LLC

[EMPLOYMENT LAW]

In Morrison v. Nana Worleyparsons, LLC,[1] the supreme court held that short-term performance plans, without express indications to the contrary, do not alter at-will employment contracts.[2] Morrison, an at-will employee at Nana Worleyparsons, was placed onto a Performance Improvement Plan (“PIP”) aimed at improving his lackluster work performance and negative attitude.[3] Shortly thereafter, Morrison made an inappropriate comment to a co-worker at a work party and was fired.[4] On appeal, Morrison argued that Nana Worleyparsons both breached his contract and the implied covenant of good faith and fair dealing.[5]  The supreme court affirmed the lower court’s decision, reasoning that since the PIP did not contain any express indications changing the at-will nature of Morrison’s employment, the PIP did not alter his original at-will employment contract.[6] The court further reasoned Nana Worleyparson’s actions did not breach the implied covenants of good faith and fair dealing because their actions were both objectively and subjectively appropriate in Morrison’s particular circumstance.[7] Affirming the lower court’s decision, the supreme court held that short-term performance plans, without express indications to the contrary, do not alter at-will employment contracts.[8]

 



[1] 314 P.3d 508 (Alaska 2013).

[2] Id. at 510–12.

[3] Id. at 509.

[4] Id. at 510.

[5] Id.

[6] Id. at 511–12.

[7] Id.

[8] Id. at 510–12.