Pine River State Bank v. Mettille

Procedural History

–          Supreme court of Minnesota

–          Trial court awarded Mettille damages, and the bank appealed.


–          Mettille, an at will employee (loan officer) was fired by Griffith, for serious deficiencies in processing over $600,000 in loans.

–          In firing Mettille, Griffith failed to follow the handbook rules, given to his employees.

–          Mettille said that Griffith was bound by these authorities.

–          Griffith stated that it was ONLY a source of information, and said that it couldn’t be part of an employee’s contract because it lacked sufficient consideration.


Was there sufficient consideration by Mettille when he was handed the employee handbooks?




It is sufficient consideration if there is a benefit conferred on the promisor of a work handbook.


Mettille’s continued performance, after receiving the guidelines, despite his freedom to quit constitutes an acceptance of the banks offer and affords the necessary consideration for that offer, with the bank gaining the advantages of a more stable and, presumably, more productive work force.



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