Recently, in a nonprecedential opinion, the 3rd U.S. Circuit Court of Appeals had the opportunity in the matter of Edwards v. Geisinger Clinic to rule on whether a physician had alleged sufficient evidence to support a breach of contract claim when his employment was terminated by his employer after about a year. The physician had a belief that his term of employment was guaranteed at least until he completed a four-year program necessary for board certification. In this nonbinding decision, the 3rd Circuit affirmed the U.S. District Court for the Middle District of Pennsylvania’s decision to dismiss the physician’s breach of employment contract claim by way of summary judgment.
The case demonstrates Pennsylvania’s strong presumption of employment-at-will, even when the discharged employee may face sympathetic circumstances. It further highlights that when a physician is entering into an agreement for employment and desires a certain minimum period of employment (whether to have sufficient time to obtain board certification or for other reasons), this must be clearly set forth in the formal documents.
