On August 3, 2006, the California Supreme Court decided the case of Dore v. Arnold Worldwide, Inc. The issue before the Court was whether the use of the phrase "at any time" to define the term "at will" in an offer letter made it ambiguous as to whether the employer could terminate the employee without cause.

In Dore, the plaintiff employee, Brook Dore, was employed with an advertising firm in Colorado as a regional account director. In 1999, Dore learned that a management supervisor position was available in the Los Angeles office of Arnold Worldwide, Inc. ("AWI") (formerly known as Arnold Communications, Inc.). Dore interviewed with several AWI officers and employees.

On April 6, 1999, Dore received a three-page offer letter from an AWI Senior Vice President. The letter listed the terms of the offer to Dore including, a commencement date, compensation details, various benefits, and an explanation of his evaluation schedule. Additionally, in a separate paragraph, AWI’s letter stated: "Brook, please know that as with all of our company employees, your employment with Arnold Communications, Inc. is at will. This simply means that Arnold Communications has the right to terminate your employment at any time just as you have the right to terminate your employment with Arnold Communications, Inc. at any time." Dore read and signed AWI’s offer letter signifying his acceptance of the employment terms.

In August 2001, AWI terminated Dore’s employment. Thereafter, Dore sued AWI alleging, among other things, breach of contract and breach of the implied covenant of good faith and fair dealing. The trial court granted AWI’s motion for summary judgment on the ground that Dore could not establish the existence of either an express or an implied-in-fact agreement that his employment was terminable only for cause. Dore appealed and the Court of Appeal reversed the judgment in favor of AWI.

The Court of Appeal concluded that AWI’s offer letter was not clear and unambiguous with respect to cause for termination. The Court of Appeal reasoned that, notwithstanding the letter’s language that "your employment with Arnold Communications, Inc. is at will," by going on to define the term "at will" to mean that AWI had the right to terminate Dore’s employment "at any time," AWI impliedly relinquished the right to terminate Dore without cause. The Supreme Court granted AWI’s petition for review.

The Dore Court reversed the Court of Appeal decision on the ground that the language in the executed offer letter was unambiguous. The Court reasoned that the offer letter "plainly states that Dore’s employment with AWI was at will," and "at will when used in an employment contract normally conveys an intent employment may be ended by either party at any time without cause" (internal quotations omitted). The Court further noted that AWI’s definition of at will did not make the parties’ agreement ambiguous because the language used by AWI merely tracked the language used by the California Legislature in California Labor Code section 2922 and the Court’s decision in Guz v. Bechtel National, Inc., 24 Cal. 4th 317. 335 (2000) ("An at-will employment may be ended by either party at any time without cause, for any reason or no reason, and subject to no procedure except the statutory requirement of notice") (emphasis added). The Dore Court concluded that although "AWI’s letter defined at will as meaning at any time, without specifying it also meant without cause or for any reason, the letter’s meaning was clear."

Thus, the California Supreme Court concluded that the term "at will" may be defined simply as "at any time," without more, and it is still clear that that the relationship may be terminated at any time, with or without cause, or for any reason or no reason.