Brodie established that an employer must give consideration when it modifies a handbook from an implied for cause contract to one of at-will employment. Police Protective Ass 'n. Under Wyoming's employment jurisprudence, employment of indefinite duration is employment which may be terminated at the will of either party for any or no reason. Those decisions held that the at-will rule did not prohibit this Court from recognizing this intent and upholding the implied contract. The hospital's contention that our decisions mean that employers are held to the contract in perpetuity is not valid. In Police Protective Ass 'n. , the court reviewed a collective bargaining agreement and characterized it as continuing in perpetuity, binding two organizationsforever.
Organizations are immortal and can continue forever, whereas, humans are mortal.
In the employment context, a valid and effective disclaimer can be distributed to new employees, and eventually an employer will only employ those with an at-will status. The difference between the two situations is obvious and demonstrates that an implied handbook contract of indefinite duration does not continue in perpetuity and is not void. The hospital also expresses concern that the rule of Brodie prohibits a reduction in force for justifiable economic reasons. Brodie does not address this issue and cannot be said to prohibit it. The hospital next contends that Mariano permits the hospital, as a governmental entity, to declare void contracts which were made during the term of a previous governing body and which are not reasonable and necessary to the entity.