“Handbook provisions [regarding] job security … are enforceable.”
Pine River State Bank v. Mettille, 333 N.W.2d 622 (Minn. April 29, 1983)
The month began with All Fool’s Day on the first day of April and concludes with another noteworthy day: the 40th anniversary of a Minnesota cause of action for violations of handbooks or workplace manuals.
It’s the second ruby anniversary of a Minnesota civil claim in the first trimester of this year, following the 40th birthday of the intentional-infliction-of-distress tort 10 weeks ago. (See Perspectives: “40 years of intentional infliction in Minnesota” in the Feb. 16, 2023, edition of Minnesota Lawyer.)
This cause of action for handbook law, a workplace-related disciplinary claim, was first recognized by the Minnesota Supreme Court on April 29, 1983, four decades ago Saturday. Like its 40-year-old intentional infliction counterpart, it has experienced peaks and valleys over the past four decades and has for a number of legal and pragmatic reasons, come to be a shallow claim for most litigants seek to recover damages for violation of provisions in manuals used in their workplaces.
The 40th anniversary of its adoption provides an opportune occasion to glance at how manual labor law evolved and declined in Minnesota jurisprudence since its inception in 1983.
That provisions in employment handbooks or manuals may be enforceable in a disciplinary context stems from Pine River State Bank v. Mettille, 333 N.W.2d 622...
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