McDonald v. Mobil Coal Producing, Inc. 820 P.2d 986 (Wyo. 1991) McDonald worked for Mobil. He got fired due to rumors of sexual harassment. McDonald sued Mobil, claiming that his employee handbook constituted a contract and that Mobil was in breach. The employee handbook gave specific procedures for deal with sexual harassment complaints, and Mobil had not followed those procedures. On the other hand, the employee handbook explicitly said that it was "not a comprehensive policy and procedures manual, nor an employment contract." The Trial Court granted summary judgment to Mobil, and McDonald appealed. McDonald claimed he was led to believe that Mobil would be bound by its own employee handbook procedures in dealing with the harassment complaints. Mobil argued that it had retained the right to fire McDonald at any time for any reason, and the employee handbook was only a guide, not a requirement. The Wyoming Supreme Court reversed and remanded to see if promissory estoppel applied to the situation. The Wyoming Supreme Court looked at the disclaimers in the handbook, and found that they were inadequate to prevent confusion. The handbook itself didn't say that it wasn't binding on the employer, and a reasonable person could get confused and think that it was. Therefore the disclaimers were held to not be binding on McDonald. The Court chose to follow the objective theory of contract formation (as opposed to the subjective theory). It doesn't matter if Mobil didn't subjectively intent to make a contract with McDonald if a reasonable person in McDonald's shoes would think that Mobil did make a contract, this is the objective theory. Under the objective theory the court has to decide whether there's any possibility that a reasonable person could think such a thing. If there is, then the question should be allowed to go to a jury. In a concurring opinion it was argued that the Court should say as a matter of law that Mobil's employee handbook constituted a legally binding promise from Mobil to McDonald and that the only issue for the trial court should be Mobil should have been forbidden from firing McDonald without cause. In a dissent it was argued that there's nothing more that Mobil could have done to make the employee know that they didn't intend to enter an employment contract. The dissent argued that the Court's decision could conceivably outlaw at-will employment, and that this is bad from a policy standpoint.