A terminated at-will employee was not entitled to damages for breach of implied contract for his employer’s alleged failure to follow disciplinary procedures outlined in an employee policy manual where the manual clearly stated that it did not alter employees’ at-will status, a divided 10th U.S. Circuit Court of Appeals ruled Feb. 1, reversing a trial verdict for the employee (Bowen v. Income Producing Management of Oklahoma Inc., 10th Cir., Nos. 98-5037 and 98-5051, 2/1/00).
The jury correctly denied recovery on the employee’s Americans With Disabilities Act claim, however, due to a lack of evidence that injuries from an on-the-job shooting incident substantially limited his ability to work, Judge Paul J. Kelly Jr. wrote for the court.
