Grouse v. Group Health Plan, Inc. Case Brief Summary | Law Case Explained

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Grouse v. Group Health Plan, Inc. | 306 N.W.2d 114 (1981)

At-will employment gives employers and employees equal freedom to end their professional relationship for any reason at any time. But what if an employer makes an offer only to end the relationship before it begins? In Grouse versus Group Health Plan, Incorporated, the Minnesota Supreme Court considered an employer’s liability for revoking an offer after the prospective employee had quit his current job.

John Grouse was a retail pharmacist at Richter Drug in Minneapolis. Grouse applied for a clinical pharmacist position at Group Health Plan, Incorporated, which offered better compensation. A few weeks later, Grouse accepted an employment offer from Cyrus Elliot, Group Health’s chief pharmacist. Grouse told Elliot he had to give Richter two weeks’ notice. Later, Grouse submitted his resignation after Elliot called back to ask whether he’d given his notice. That afternoon, Grouse declined a second job offer based on Elliot’s offer.

Group Health’s hiring requirements included a background check and a favorable reference. Unfortunately, Eliot couldn’t obtain a favorable reference for Grouse. On Grouse’s job application, he requested that Group Health not request a reference from Richter, as Grouse hadn’t informed his current employer he was seeking new employment. But previous employers claimed they hadn’t worked closely enough with Grouse to assess his capabilities. After completing his final day at Richter, Grouse notified Elliot he was free to begin work at Group Health. Elliot explained that because he couldn’t obtain a favorable reference for Grouse, management had revoked Grouse’s offer and hired another candidate.

After struggling to secure employment, Grouse sued Group Health for breach of contract, seeking damages for lost wages. The trial court dismissed the case, ruling the parties never formed a contract. Grouse appealed to the Minnesota Supreme Court.

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