Eichelberger began working with Sinclair on December 5,
2005. On her date of hire, she received a Sinclair employee handbook and
benefits package which, among other provisions, explicitly stated that she was
an employee at-will. The handbook specifically and expressly informed
Eichelberger that she did not have any contract of employment with Sinclair for
any time period. It also alerted Eichelberger to Sinclair's employee benefits
plan. All employees were to complete a 90-day probationary period before
becoming eligible to receive employee benefits, including disability insurance
benefits. The insurance policy also explicitly stated that it would not cover
pre-existing conditions. After receiving and reviewing the materials,
Eichelberger signed a statement stating that she understood those employment
conditions. On June 1, 2006, Eichelberger completed the 90-day probationary
period.
Prior to that date, in May 2006, Eichelberger learned that
she was pregnant with quadruplets. She informed her supervisors that, due her
multiple-birth pregnancy and its resultant complications, her doctor had placed
her on bed-rest until her due date. Eichelberger alleged that her supervisor
assured her that she could return to her position following the birth of her
babies. While on bed-rest, Eichelberger was diagnosed with edema, for which she
sought disability benefits from Sinclair's insurer.
Sinclair's insurer denied Eichelberger's request for
benefits, informing Eichelberger that because she confirmed her pregnancy in May
2006, but did not become eligible for disability benefits until June 1, 2006,
her pregnancy and resultant edema were considered "pre-existing conditions."
Such pre-existing conditions were specifically excluded by the terms of the
insurance policy. On September 8, 2006, while Eichelberger was still on
bed-rest, Sinclair terminated her position, stating that her absence from work
was not covered by any absence or benefit plan. Eichelberger filed suit shortly
thereafter.
In reviewing Sinclair's Motion for Summary Judgment on
Eichelberger's misrepresentation claims, the District Court for the District of
Maryland noted that Eichelberger failed to present any proof to support her
allegations. As to her misrepresentation claims, Eichelberger had provided no
evidence to show that she justifiably relied on the alleged misrepresentations,
which is required by both intentional and negligent misrepresentation torts.
Because an at-will employment contract can be terminated at any time for any or
no cause, the court held that an at-will employee cannot reasonably rely on an
employer's statements that a job will be held until the employee returns from a
long absence. This is especially true when an employee, like Eichelberger, has
been clearly informed of her at-will employment status. Further, the court
noted, because Eichelberger's doctor had ordered her to stop working once she
was diagnosed with edema, Eichelberger would have stopped working regardless of
whether she received those oral reassurances. Therefore, she could not prove
that she relied to her detriment on her supervisors' alleged misrepresentations.
On these counts, the court granted Sinclair's Motion for Summary Judgment.
In Eichelberger v. Sinclair Broadcasting Group, Inc., the
District Court for the District of Maryland made clear that at-will employees
cannot reasonable rely on their employer's reassurances that a position will be
held for them during a long-term absence. An at-will employment contract, which
is of indefinite duration, is terminable by either party at any time. Oral
reassurances that contradict this notion will not change this principle. More
broadly, this case stands for the proposition that at-will employees will be
precluded from suing employers for negligent or intentional misrepresentations
when the employees are made expressly aware of their employment conditions.