Colnoe v. Honeywell International, Inc.

Background

Blojay Colnoe applied for Honeywell’s Principal Supplier Recovery Specialist position in November 2018. The position required “80% + travel to work at the supplier’s location.” During the screening process, written materials indicated that Colnoe was comfortable traveling and willing to relocate to several listed locations. Honeywell’s hiring personnel testified that an application would not proceed if a candidate could not meet the travel requirement.

Colnoe participated in three interviews and was offered the job. The offer letter stated that the position would be based at Honeywell’s Minneapolis office, but it did not say where Colnoe’s assigned suppliers would be located. After he began working, Honeywell assigned him to a supplier in Cedar Rapids, Iowa. Colnoe told Honeywell that family and schooling obligations prevented him from working full-time in Iowa. Honeywell determined that it had no other supplier assignment meeting his travel restrictions and terminated his employment.

Colnoe sued under Minnesota’s doctrine of promissory estoppel. He claimed that, during his first interview, Honeywell employee Doug Scites promised that Colnoe would be assigned to a Minnesota supplier. Honeywell removed the case to federal court and moved for summary judgment.

Legal standard

The court explained that summary judgment is proper when there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The evidence must be viewed in the light most favorable to the party opposing the motion, but that party must identify specific evidence supporting a trial-worthy factual dispute.

Under Minnesota law, a promissory-estoppel claim requires a clear and definite promise, an intended and actual reliance on that promise, and enforcement necessary to prevent injustice.

Court’s analysis

The court did not decide whether Minnesota law places broader limits on promissory-estoppel claims involving at-will employment. It concluded instead that Colnoe had not shown a genuine factual dispute about whether Scites made a clear and definite promise regarding the location of Colnoe’s work.

Colnoe relied exclusively on his own testimony about the first interview. He testified that he explained his desire to work with Minnesota suppliers so he could spend more time with his family and pursue further schooling, and that Scites responded, in substance, “okay, that is fine.” The court held that this testimony did not establish an unambiguous commitment to assign Colnoe to a Minnesota supplier.

The court also considered the full record. The job description required extensive travel to supplier locations, the offer letter did not promise a Minnesota supplier assignment, and Honeywell personnel communicated that Colnoe could be assigned to an out-of-state supplier. Neither party offered testimony from Scites, and the record contained no evidence that Scites later acknowledged the alleged promise when Colnoe objected to the Iowa assignment. The court therefore found that Colnoe’s testimony, standing alone, was insufficient to create a genuine factual dispute.

Disposition

The court GRANTED Honeywell International, Inc.’s Motion for Summary Judgment and ordered that judgment be entered accordingly.