Hall v. City of Plainview
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The Supreme Court affirmed in part and reversed in part the judgment of the district court granting the City of Plainview's motion to dismiss Donald Hall's contract and statutory claims, holding that the City had a contractual obligation to pay accrued paid time off (PTO) to Hall.
After the City terminated Hall's employment as manager of the City's municipal liquor store it refused to pay Hall accrued PTO due to Hall's failure to provide sufficient notice per the requirements of the City's personnel policies and procedures manual. Hall sued the City for breach of contract and violation of Minn. Stat. 181.13. The district court dismissed Hall's contract and statutory claims. The Supreme Court remanded the case, holding (1) disclaimer provisions in the City's employee handbook stating that the handbook's policies should not be construed as a contract did not unambiguously allow the City to refuse to pay accrued PTO in accordance with the employer policy set forth in the handbook; and (2) Minn. Stat. 181.13(a) does not create an independent substantive right to payment of accrued PTO in the absence of a contract between the employer and employee.
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