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September 20, 2023

Former employees of a candidate's election campaign organization challenged their termination after the candidate's withdrawal from the campaign

Plaintiffs-Appellants in this appeal to the United States Court of Appeals, Second Circuit, are fifty former field employees of defendants "Michael Bloomberg and Mike Bloomberg 2020, Inc." [Campaign], which sought to promote and secure the Democratic presidential nomination for Michael Bloomberg.

Plaintiffs contended that Campaign recruited them to the job by promising employment through November 2020, but reneged on that promise when the Campaign dismissed Plaintiffs shortly after Bloomberg withdrew from the race in March of 2020. Plaintiffs, alleging "fraudulent inducement and promissory estoppel", challenged a federal district court’s dismissal of their complaint, with prejudice and without leave to amend.

The Circuit Court said it reviewed de novo "both the district court’s dismissal under Rule 12(b)(6) and its denial of the request to amend [the complaint] on the basis of futility," citing Chambers v. Time Warner, Inc., 282 F.3d 147,  and Panther Partners Inc. v. Ikanos Commc’ns, Inc., 681 F.3d 114.

Concluding that "(1) Plaintiffs are unable to prove the reasonable reliance required for their claims because of the at-will nature of their employment agreement,* and (2) Plaintiffs would not be able to survive dismissal even if granted leave to amend", the Circuit Court sustained the district court's ruling.

* A footnote, Footnote 4, in the Circuit Court's decision notes Campaign's offer of employment letter states “[t]he nature of your employment at the [Campaign] is and will continue to be ‘at will,’ as defined by applicable law, meaning that either we or you may terminate your employment at any time, with or without notice and with or without cause, for any reason or for no reason.” Further, observed the court, Campaign's employee handbook states “[y]our employment with the [Campaign] is ‘at will,’ which means that it is for no definite period of time, and may be terminated at any time by either you or the [Campaign], with or without cause, notice or procedural requirements.”

Click HERE to access the text of the Circuit Court's decision posted on the Internet.

 

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