Ferrett v. General Motors Corp.

475 N.W.2d 243, 438 Mich. 235, 6 I.E.R. Cas. (BNA) 1285, 1991 Mich. LEXIS 2117
CourtMichigan Supreme Court
DecidedAugust 27, 1991
DocketDocket 88489; Calendar 3
StatusPublished
Cited by32 cases

This text of 475 N.W.2d 243 (Ferrett v. General Motors Corp.) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ferrett v. General Motors Corp., 475 N.W.2d 243, 438 Mich. 235, 6 I.E.R. Cas. (BNA) 1285, 1991 Mich. LEXIS 2117 (Mich. 1991).

Opinion

Levin, J.

This Court granted leave to appeal, limited to the issue whether the circuit court erred in granting General Motors Corporation summary disposition dismissing Darwin Ferrett’s claim of negligent evaluation. 1 We agree with the Court of Appeals that the circuit court did not err in dismissing Ferrett’s claim of negligent evaluation.

i

Ferrett was a test driver for General Motors Corporation at its proving grounds in Milford from November, 1973, until the termination of his employment in August, 1986. Although otherwise a good employee, Ferrett’s thirteen years with gm *237 included problems with absenteeism. From early 1983 until the termination of his employment in August, 1986, he was made aware that unless he maintained consistently good attendance, his position with gm would be in jeopardy.

As a salaried worker for gm, Ferrett’s employment relationship was the subject of a handbook entitled "Working with General Motors.” The handbook advised workers that their performance would be assessed at least twice annually by their supervisor, and that the assessment program consisted of four main parts: performance planning, informal discussions, written appraisal, and appraisal interview. Performance Improvement Plans, though not specifically discussed in the handbook, were a part of the appraisal and evaluation program.

The employee handbook also contained the following statements, the first, under the heading "Employment Status”:

As a regular employe, your employment is on a calendar month-to-month basis.
[T]he policies and procedures in the booklet do not constitute a legal contract, and do not modify the month-to-month employment relationship ....

Beginning in 1983, Ferrett received a number of oral and written warnings from his supervisor that his deteriorating attendance was becoming a significant problem for management. By January, 1984, Ferrett’s attendance problems caused his overall performance rating to drop from "[g]ood [c]ompetent” to "[n]eeds [s]light [ijmprovement because of excessive absenteeism . . . .”

Ferrett was placed on a Performance Improvement Plan for ninety days, during which time he *238 maintained an acceptable attendance record. After the Performance Improvement Plan was successfully completed, however, Ferrett’s attendance slackened. In 1985, a memorandum was placed in Ferrett’s file documenting the recurring attendance problems.

In 1986, Ferrett was placed on a second ninety-day Performance Improvement Plan that specified strict performance standards and stated that if Ferrett did not reach an acceptable attendance level by the end of the ninety days, his performance rating would be reappraised and management would recommend termination of his employment.

During this ninety-day period, Ferrett’s performance again improved. At the end of the ninety days, Ferrett’s supervisor noted that Ferrett had successfully completed the Performance Improvement Plan, and he was reevaluated to "[g]ood [competent.” The supervisor also noted that he had advised Ferrett that "his performance improvement must be sustained in the future or management will recommend termination.” In an appraisal five days later, the supervisor noted that he had told Ferrett "it is very important that he maintain a good attendance record and schedule his time off in the future or management will [recommend] termination.”

Between April 22, 1986, the date of the appraisal following the conclusion of the second Performance Improvement Plan, and August 21, 1986, Ferrett missed ten days’ work. He submitted a note for the last of the ten absences, on August 20, 1986, explaining that his mother had been in an accident, and that he had gone to the hospital to visit her. According to a report to the file written by Ferrett’s supervisor, the supervisor reminded Ferrett that under the terms of the last *239 Performance Improvement Plan, he was to maintain perfect attendance and notify the supervisor when he would not be at work, and Ferrett promised to do so. The supervisor did not, however, tell Ferrett that his employment was about to be terminated due to excessive absenteeism.

One week later, on August 29, 1986, Ferrett was discharged from further employment with gm.

ii

Ferrett commenced this action alleging breach of contract and negligent evaluation. The circuit court granted gm’s motion for summary disposition on both the contract and the negligent-evaluation counts. On the breach-of-contract count, the court held that there was no genuine issue of material fact concerning the "at will” status qf Ferrett’s employment. On the negligent-evaluation count, the court held that Ferrett’s claim was not based on a legal duty independent of the employment relationship.

The Court of Appeals affirmed.

hi

The Court of Appeals, and the federal courts in the Sixth Circuit applying Michigan law, have, with two exceptions, 2 held that an employee may not maintain a tort action for negligent evalua *240 tion. Those cases, relying on this Court’s decision in Hart v Ludwig, 347 Mich 559; 79 NW2d 895 (1956), generally reason that an employee may not maintain such an action because he does not seek to recover for breach of a duty separate and distinct from any breach of contract.

Loftis v GT Products, Inc, 167 Mich App 787, 796; 423 NW2d 358 (1988), typifies Court of Appeals cases holding that an employee may not maintain an action for negligent evaluation on the basis of an asserted breach of an employment contract. The employee claimed that his employer was required under the terms of the employee handbook to evaluate its employees and to use reasonable care in performing an evaluation.

The Court held that the employee could not maintain an action because his complaint "did not allege a breach of duty . . . distinct from the breach of contract, an essential element of a cause of action for negligent evaluation . . . .” The Court read this Court’s holding in Hart to mean that "[a] tort action will lie if a relationship or situation of peril exists that would give rise to a legal duty without the need to enforce the contract promise itself.” 3 Id. at 797.

*241 A number of panels of the Court of Appeals 4 and of the United States Court of Appeals for the Sixth Circuit 5 have reached the same result.

*242 IV

We decline to recognize an action in tort for negligent evaluation. An action may be maintained, if at all, only for breach of a contractual obligation to evaluate.

In Hart v

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Bluebook (online)
475 N.W.2d 243, 438 Mich. 235, 6 I.E.R. Cas. (BNA) 1285, 1991 Mich. LEXIS 2117, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ferrett-v-general-motors-corp-mich-1991.