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Kauffman v. International Brotherhood of Teamsters

The D.C. Court of Appeals affirmed the D.C. Superior Court's grant of summary judgment to the defendant in a case in which the plaintiff sued his employer for breach of an agreement to provide the plaintiff with a monthly housing allowance. The trial court, implicitly relying on the appeals court decision in National Rifle Association v. Ailes (D.C. 1981), granted summary judgment to the employer, and the appeals court affirmed.

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Argued May 16, 2008

Before WASHINGTON, Chief Judge, and FARRELL and GLICKMAN, Associate Judges.

Kauffman sued his employer, International Brotherhood of Teamsters (hereafter IBT), in Superior Court for breach of an agreement to provide him with a monthly housing allowance. IBT had paid Kauffman the allowance starting in 1993, but in April 1996 discontinued it, prompting this suit. IBT defended by arguing in part that, as an at-will employee, Kauffman had impliedly agreed to elimination of the housing allowance by remaining an employee of IBT for years (namely, three) after the change took effect with his knowledge. The trial court, implicitly relying on our decision in National Rifle Ass’n v. Ailes, 428 A.2d 816 (D.C. 1981), granted summary judgment to IBT. We affirm.

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