Warning

Info

Table of Contents
Okapi13, SLS '24 |

0 0

Back to briefs

Elmer Hillesland v. Federal Land Bank Association of Grand Forks

(1987)

North Dakota Supreme Court - 407 N.W.2d 206

Tags: Good Faith

tl;dr:

There is no general duty to engage in good faith when determining whether to fire an at-will employee.

Video Summary


Case Summary

In the 1987 case Hillesland v. Federal Land Bank Association of Grand Forks, Elmer Hillesland, a former executive of the Association, sued them and Federal Land Bank of St. Paul (the Bank) for wrongful discharge. Hillesland had helped his sons purchase a farm from financially struggling Association customers. Although the Association's board approved the transaction, the Bank's review committee expressed conflict of interest concerns. After the sale, the Bank fired Hillesland, accusing him of violating written ethics codes, tarnishing the banks' reputations, and demonstrating poor business judgment. Hillesland claimed the Bank and Association had violated the Farm Credit Act, breached contracts, discriminated based on his age, and wrongfully interfered with his contract.

The district court dismissed Hillesland's claims, and the Supreme Court agreed, finding none of his claims could withstand summary judgment. The court ruled there was no implied right to sue for wrongful discharge and no breached contracts as Hillesland was an at-will employee. Additionally, they found no age discrimination or tortious interference with contracts by the Bank, as Hillesland could not prove malicious or unjustifiable actions.

This case is important because it highlights the legal concept of wrongful discharge, where an employee accuses their employer of unlawfully or unfairly ending their employment. This claim can stem from statutory, common, contractual, or implied laws, balancing employees' rights to job stability with employers' rights to manage their businesses and staff.

ICRAIssue, Conclusion, Rule, Analysis for Elmer Hillesland v. Federal Land Bank Association of Grand Forks

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Elmer Hillesland v. Federal Land Bank Association of Grand Forks case brief summary.

Enjoy unlimited access with our 14-day free trial.

Facts & HoldingElmer Hillesland v. Federal Land Bank Association of Grand Forks case brief facts & holding

Facts:Plaintiff Hillesland was an “at-will” employee (CEO) of Defendant Federal...

Holding:Judgment affirmed. Nothing in Hillesland's contract conflicts with the general...

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Elmer Hillesland v. Federal Land Bank Association of Grand Forks case brief summary.

Enjoy unlimited access with our 14-day free trial.

DeepDiveHighlight a legal term to see the definition

Font size -+
Elmer Hillesland v. Federal Land Bank Association of Grand Forks | Case Brief DeepDive
Majority opinion, author: ERICKSTAD, Chief Justice.
Level 1
Click below 👇 to DeepDive

The former CEO of the Federal Land Bank Association of Grand Forks sued the bank and the Federal Land Bank of St. Paul for violating the Farm Credit Act, breaching his employment contract, age discrimination, and tortious interference with his employment contract. The district court dismissed the case, and the plaintiff appealed on five issues, including whether there is an implied private right of action for wrongful discharge under the Farm Credit Act. The court found that there is no implied private right of action under the Cort test for wrongful discharge under the Farm Credit Act. The court also ruled in favor of the employer in an employment contract dispute where the employee claimed permanent employment and discharge only for good cause, but failed to provide evidence to support this claim. The court held that statements made by an employer during recruitment do not create a contractual agreement for permanent employment or discharge only for good cause. The court declined to follow California's interpretation of an implied covenant of good faith and fair dealing in employment contracts, which prohibits an employer from engaging in bad faith action extraneous to the contract, combined with the obligor's intent to frustrate the employee's enjoyment of contract rights. The at-will rule in North Dakota allows either party to terminate an employment without cause or notice.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Elmer Hillesland v. Federal Land Bank Association of Grand Forks case brief summary.

Enjoy unlimited access with our 14-day free trial.

Dissenting opinion, author: PEDERSON, Surrogate Justice
Level 1
Click below 👇 to DeepDive

Surrogate Justice Pederson's dissenting opinion in the case agrees with the majority opinion except for the dicta disposition of issue number 3, which concerns the Implied Covenant of Good Faith and Fair Dealing. Pederson believes that even though the termination was not "without cause," there is still an obligation to not act in bad faith in all relationships between civilized persons. In cases of aggravated breach or unconscionable conduct, the court should provide a remedy. Justice Meschke concurs with this opinion. It is noted that the lower court may have erred in its decision.

🤯 High points 🤯Key points contributed by students on LSD

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Elmer Hillesland v. Federal Land Bank Association of Grand Forks case brief summary.

Enjoy unlimited access with our 14-day free trial.

LSD+ Case Briefs

Features

  • DeepDive for detailed case analysis
  • Over 50,000 existing case briefs
  • Instant briefs for another 6,000,000 cases
  • Highlight dictionary for legal term definitions
  • Social learning with chat and high points

Over 50,000 Cases Briefed

LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.

14-Day Free Trial

Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.

Integrated Legal Dictionary

Lawyers and judges love to use big words. And Latin, for some reason.

Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.

DeepDive

DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.

Brief anything. Instantly.

Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.

Social Learning with Chat and High Points

Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.

Real-Time Brief Feedback

Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.

Elmer Hillesland v. Federal Land Bank Association of Grand Forks

Chat for Elmer Hillesland v. Federal Land Bank Association of Grand Forks
brief-108
👍 Chat vibe: 0 👎
Help us make LSD better!
Tell us what's important to you
LSD+ is ad-free, with DMs, discounts, case briefs & more.