In 1884 the Supreme Court of Tennessee decided Payne v. Western & Atlantic Railroad. It held that employers “may dismiss their employees at will, be they many or few, for good cause, for no cause or even for cause morally wrong, without being thereby guilty of legal wrong.”
Montana has changed this by law. Its Wrongful Discharge from Employment Act of 1987 makes a dismissal wrongful when “the discharge was not for good cause and the employee had completed the employer’s probationary period of employment.” Montana is described as “the only U.S. state that has chosen to statutorily modify the employment at-will rule.”