Patricia Williams Howard v. Wolff Broadcasting Corporation, 611 So. 2d 307

Summary

The employee claimed that her employment contract was not terminable at will because there was an implied covenant that the employer would not discriminate against her on the basis of race, gender, religion, or national origin, based upon the FCC regulations codified at 47 C.F.R. § 73.2080. The court disagreed, finding that the provisions of 47 C.F.R. § 73.2080 did not become a binding promise once they were accepted by the employee through her continuing to work and did not transform her at-will employment relationship with into a permanent one. The employee also claimed that the employer through a sign posted in the station lobby, expressly represented to the employee when hiring her that she would not be discriminated against on the basis of sex. She alleged that the representation was false and was known to be false when it was made. The court affirmed the grant of summary judgment on the fraud claim, finding that the employee produced no substantial evidence that the employer made...