Guz worked for Bechtel (BNI) for 22 years. He had a good employment record. Bechtel's personnel policy stated that its employees were at-will. It also stated that employees could be terminated for unsatisfactory performance or because of a reduction in workload or a reorganization. Management decided to cut the budget for Guz's division. Guz and others were fired. This occurred at a time of good profits for the company. The duties Guz performed were shifted to other employees. He applied for other positions at BNI, but he was rejected without reason.

1. The high court held that employment-at-will is difficult to overcome by a claim of implied contract. Is there an incentive for employers to make it clear to employees that they are strictly at-will and there is no assurance of continued employment?
2. Is there an employment contract? Guz had to follow the requirements of his employer; what consideration did the employer give?