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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).

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