"Semple concedes that his employment with Federal Express was at-will, but argues that an exception to the at-will-employment doctrine places his termination outside its application. Under South Dakota law, '[a]n employment having no specified term may be terminated at the will of either party on notice to the other, unless otherwise provided by statute.' The at-will employment doctrine applies to wrongful termination claims. Accordingly, for Semple to have a valid claim for wrongful termination, his claim must fit within one of the limited exceptions South Dakota has recognized to the at-will employment doctrine. To date, South Dakota has only exempted terminations: (1) that violate public policy; (2) of employees with 'for cause only' agreements or implied 'for cause only' agreements; and (3) of employees who accept employment after promises of a promotion."
[After it held that no exception was shown to apply, the court affirmed summary judgment in favor of Federal Express].