Sullivan v. Heritage Foundation

399 A.2d 856, 115 L.R.R.M. (BNA) 4621, 1979 D.C. App. LEXIS 299
CourtDistrict of Columbia Court of Appeals
DecidedMarch 16, 1979
Docket12784, 12839
StatusPublished
Cited by52 cases

This text of 399 A.2d 856 (Sullivan v. Heritage Foundation) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sullivan v. Heritage Foundation, 399 A.2d 856, 115 L.R.R.M. (BNA) 4621, 1979 D.C. App. LEXIS 299 (D.C. 1979).

Opinion

GALLAGHER, Associate Judge:

James T. McKenna and John Sullivan appeal 1 from grants of summary judgment for the Heritage Foundation (Heritage) on breach of contract claims and on McKenna’s individual cause of action for malicious injury to business reputation. Their appeal requires us to consider (1) whether the trial court erred in ruling, as a matter of law, that the hirings were for an indefinite period, terminable at the will of either party, and (2) whether appellant McKenna’s evidence presented a jury question on his claim of malicious injury to reputation. 2 Finding the summary judgments against appellants properly granted, we affirm.

A. Breach of Contract

Until their dismissal on April 3, 1976, McKenna and Sullivan were employed by Heritage, a tax-exempt corporation engaged in public interest research. McKen-na’s duties as General Counsel of Heritage began on February 1, 1974, when he transferred from the Center for Public Interest, the predecessor of Heritage, at the request of a major donor. Sullivan’s employment, in the capacity of Administrator and Funding Director, commenced ' on January 1, 1975, at a salary of $36,000 per annum. He moved from Boston to take the job, in reliance on a representation that the Heritage by-laws set an annual contract for all officers. According to Sullivan’s deposition testimony,

[i]t was my understanding that I would remain at the Heritage Foundation until such time as I would either retire or for whatever reason, left on my own or if I were, in fact, to breach my contract with the Heritage Foundation, I suppose they’d have the right to terminate me.

Appellants contend that as officers and key employees of Heritage they were beneficiaries of annual contracts running from one Board of Trustees meeting to the next. (The annual meetings were held on March 15.) 3 This contract, they allege, was breached by their dismissal without cause.

In denying Heritage’s motion for judgment on the pleadings against plaintiff Sullivan based on failure to set forth a factual basis for a contract, the trial court stated:

While there appears to be a serious question concerning the existence of a contract, if plaintiff is only relying on the by-laws and the applicable statute,[ 4 ] such *859 a reliance is not clear from the complaint. The fact that the plaintiff cites the bylaws does not prevent him from relying upon a written or oral contract entered into by the Board pursuant to the authority granted in the by-laws . . . . It is certainly not clear from the complaint, that the plaintiff relies only on the statute and the by-laws.

After defendant’s motion for summary judgment, however, the trial court concluded:

Subsequent discovery has made it clear that plaintiff does in fact rely solely upon the by-laws and the provisions of the D.C.Code and he admits that no written or oral contract for a fixed period of employment was ever entered into between him and the defendant.

In reviewing a grant of summary judgment, it is our responsibility to determine whether there was any issue of fact pertinent to the ruling and, if not, whether the substantive law was correctly applied. See Super.Ct.Civ.R. 56; 6 J. Moore, Federal Practice and Procedure ¶ 56.27[1]. A summary judgment is appropriate only where no genuine issue of material fact exists. See, e. g., Bennett v. Kiggins, D.C.App., 377 A.2d 57, 59 (1977). Thus, to survive the summary judgment motion, plaintiffs need only show that “there is sufficient evidence supporting the claimed factual dispute to require a jury or judge to resolve the parties’ differing versions of the truth at trial.” International Underwriters, Inc. v. Boyle, D.C.App., 365 A.2d 779, 782-83 (1976).

Having admitted during discovery that no fixed-term oral or written contract existed, on appeal appellants rest their claims on implied contracts. They contend that the employment term of an implied contract is á question of fact for a jury and point to the by-laws, statute and other circumstances to support a finding of an implied annual contract.

The duration of a contract may be a question of fact when the evidence is conflicting. See, e. g., Burgess v. Grooms, D.C.Mun.App., 81 A.2d 338, 339 (1951). Rather than establishing a factual dispute, however, appellants’ pleadings, affidavits and depositions are in agreement with defendant’s statement of uncontested material facts as adopted by the trial court. There is no conflicting evidence of an agreement to employ for a fixed period or of circumstances from which such an agreement could be inferred. Compare Heflin v. Silverstein, 132 U.S.App.D.C. 7, 405 F.2d 1075 (1968) (oral agreement to render services as counsel for one year allegedly breached. Motion for summary judgment denied because there was “sharply conflicting evidence respecting highly material facts.”). More than conclusive allegations in the pleadings or appellants’ belief in the permanence of employment are necessary to raise a material issue of fact precluding the grant of summary judgment. See, e. g., Bloomgarden v. Coyer, 156 U.S.App.D.C. 109, 479 F.2d 201 (1973).

Given the undisputed nature of the facts in this case, 5 the propriety of the summary judgment rests on the trial court’s interpretation of law. The issue boils down to whether the facts, statute and by-laws establish an annual contract as a matter of law. Initially, the existence of an employment contract must be distinguished from the duration of the employment period pro *860 vided by a contract. At a minimum, Heritage promised to pay for services when rendered at a specified salary rate, and appellants promised to render services. Unless otherwise agreed, however, mutual promises to employ and to serve at the agreed rate create obligations terminable at will by either party. See, e. g., Taylor v. Greenway Restaurant, Inc., D.C.Mun.App., 173 A.2d 211 (1961); Lyons v. Capital Transit Co., D.C.Mun.App., 62 A.2d 312 (1948); 2 Restatement (Second) of Agency § 442 (1958). It has been long settled in this jurisdiction that

where no such intent [to enter into a contract for a fixed period] is clearly expressed and, absent evidence which shows other consideration than a promise to.

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Bluebook (online)
399 A.2d 856, 115 L.R.R.M. (BNA) 4621, 1979 D.C. App. LEXIS 299, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sullivan-v-heritage-foundation-dc-1979.