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4782 A written agreement specifying that employment is at will may subsequently be modified by oral assurances to the contrary, or by employer's conduct implying that the employee will not be terminated except for cause; a jury's findings by special verdict that a written at-will employment agreement was effective, but that there was a subsequent implied agreement to the contrary, were inconsistent, requiring a new trial; a judgment notwithstanding the verdict (JNOV) is not appropriate unless a directed verdict would have been, so a trial judge who found that there was a question of fact for the jury may not subsequently grant a motion for JNOV.CitationSTILLWELL v SALVATION ARMY (At-will Employment) 167 CA4 360 [See: LabC 2922; Guz v Bechtel 24 C4 317, T/AT 11/00; Kovatch v Cal Cas 65 CA4 1256, T/AT 9/98; Jones & Matson v Hall 155 CA4 1596, T/AT 11/07]
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