On February 16, 1883, the Western & Atlantic Railroad gave an order to its workers in Chattanooga, Tennessee: “Any employe of this company on Chattanooga pay-roll who trades with L. Payne from this date will be discharged.” Payne sued the railroad and lost.
In 1884 the Tennessee Supreme Court decided Payne v. Western & Atlantic Railroad. It wrote: “All may dismiss their employes at will, be they many or few, for good cause, for no cause or even for cause morally wrong.” Doing so, the court said, is not a legal wrong.