<P> Eleven US states have recognized a breach of an implied covenant of good faith and fair dealing as an exception to at - will employment . The states are: </P> <Ul> <Li> Alabama </Li> <Li> Alaska </Li> <Li> Arizona </Li> <Li> California </Li> <Li> Delaware </Li> <Li> Idaho </Li> <Li> Massachusetts </Li> <Li> Montana </Li> <Li> Nevada </Li> <Li> Utah </Li> <Li> Wyoming </Li> </Ul> <P> Court interpretations of this have varied from requiring "just cause" to denial of terminations made for malicious reasons, such as terminating a long - tenured employee solely to avoid the obligation of paying the employee's accrued retirement benefits . Other court rulings have denied the exception, holding that it is too burdensome upon the court for it to have to determine an employer's true motivation for terminating an employee . </P> <P> Although all U.S. states have a number of statutory protections for employees, most wrongful termination suits brought under statutory causes of action use the federal anti-discrimination statutes which prohibit firing or refusing to hire an employee because of race, color, religion, sex, national origin, age, or handicap status . Other reasons an employer may not use to fire an at - will employee are: </P>

The basis of the employment-at-will doctrine is found in common law principles