Thompson, J.

We state the material facts which were before the court as made by the plaintiff’s evidence; and for the purpose of our consideration of the propriety of the ruling of the trial court in granting the defendant’s motion for a peremptory verdict and entering judgment thereon, we take them as true. The governing rule at this point is well established.

The ease as made by the plaintiff’s evidence is that he was a skilled pressman, and had been in the employ of the defendant-corporation at Mason City for many years prior to 1959. In the autumn of that year he had an opportunity to obtain a steady job with the Stoyles Printing Company, also of Mason City. He knew that the defendant’s business was often slack in the winter, and contacted G. C. Yenz, the president of defendant, to learn whether he would have steady work with it. This resulted, after some negotiations, in an arrangement expressed in a letter from Yenz to the plaintiff, which is set out:

*1223“Oct. 21, 1959

Mr. Harry Hanson,

Starting today Oct. 21, I will guarantee you 40- hours work per week thru out the entire year each year untill you retire of your own choosing.

/s/ G. C. Venz, Pres.”

The plaintiff thereupon elected to remain in the employ of the defendant, and did so until October 21, 1961, when he was discharged, without cause. His hourly rate of pay was $2.77%. He asks “damages in. the past and in the future at the rate of $2.77% per hour for 40 hours per week throughout the entire year for each year and until he retires, all according to the terms of the employment contract”, and for costs. At the close of his evidence the trial court granted the defendant’s motion for a directed verdict, and from the judgment entered thereon the plaintiff appeals.

I. The question before us is essentially a simple one, and has been before the courts of the various jurisdictions- many times. The rule which has been generally followed is thus set forth in 35 A. L. R. 1432: “* * * in the absence of additional express or implied stipulation as to the duration of the employment or of a good consideration additional to- the services contracted to be rendered, a contract for permanent employment, for life employment, for as long as the employee chooses, or for •other terms purporting permanent employment, is no more than an indefinite general hiring terminable at the will of either party.” This rule fits the situation before us, where the employment was to be “until you retire of your own choosing.”

Many courts have applied and followed this rule. In 1961 Judge Henry Graven of the United States District Court Northern District of Iowa, discussed it at length in Bixby v. Wilson & Company, 196 F. Supp. 889. He concluded that while he was bound to follow the Iowa law on the question, it had not been exactly passed upon by the Iowa courts, but that there were strong indications the rule stated above would be followed. In that case the plaintiffs had been employed by the defendant during a strike at its Cedar Rapids plant. They were informed that *1224their employment would be permanent. In reliance upon this promise some gave up other jobs; some gave up' farm leases; and some moved to Cedar Rapids. But the trial court held that these things were insufficient consideration to support the claimed contract for permanent employment, and rendered judgment for the defendant.

The defendant urges here lack of mutuality; that is, it contends the plaintiff was not bound to any specific or enforceable term of employment. This is true; but lack of mutuality is not always proof of want of consideration. We have said: “If the lack of mutuality amounts to a lack of consideration, then the contract is invalid. But mere lack of mutuality, in and of itself, does not render a contract invalid. * * * Though consideration is essential to the validity of a contract, it is not essential that such consideration consist of a mutual promise.” Standard Oil Co. v. Veland, 207 Iowa 1340, 1343, 224 N.W. 467, 469. We quoted this with approval in Des Moines Blue Ribbon Distributors, Inc., v. Drewrys Ltd., U.S.A., 256 Iowa 899, 906, 129 N.W.2d 731, 736.

So the lack of mutuality in itself is not fatal to plaintiff’s case, if there is other consideration. He contends that he gave up the opportunity to take other employment; that this was a detriment to him, and so furnished consideration for the agreement. But it has been repeatedly held that this is not sufficient in contracts for permanent employment, or, as the plaintiff contends here, until he should “retire of your own choosing.” In Edwards v. Kentucky Utilities Co., 286 Ky. 341, 347, 150 S.W.2d 916, 919, 135 A. L. R. 642, 646, where the plaintiff had left another job at defendant’s request on the assurance of a permanent job, the Kentucky Court of Appeals said: “But be this as it may, no consideration was paid to the appellee for the contract of employment sued on; and we are not disposed to- broaden the present rule in this state by which such contracts are construed as contracts terminable at the will of either party * * So, in Chesapeake & Potomac Tel. Co. v. Murray, 198 Md. 526, 533, 84 A.2d 870, 873, 28 A. L. R.2d 920, 926, it was held: “However, the mere giving up of a job, business or profession by one who decides to accept a contract for alleged life employment is but *1225an incident necessary on his part to place himself in a position to accept and perform the contract, and is not consideration for a contract of life employment.”

The same question was before the Michigan Supreme Court in Adolph v. Cookware Co. of America, 283 Mich. 561, 568, 278 N.W. 687, 689, where it was said:

“Plaintiff’s proofs, taken as true, showed a contract for permanent employment. Such a contract is for an indefinite period, and, unless for a consideration other than promise of services, the employment was terminable at the will of either party. Lynas v. Maxwell Farms, 279 Mich. 684 [273 N.W. 315], and cases there cited.

“The action of plaintiff in giving up the practice of his profession was but an incident necessary on his part to place himself in a position to accept and perform the contract and not a price or consideration paid to defendant for the contract of employment.” Also cited is Lord v. Goldberg, 81 Cal. 596, 22 P. 1126, 15 Am. St. Rep. 82.

The question was extensively considered in Skagerberg v. Blandin Paper Co., 197 Minn. 291, 266 N.W. 872. The plaintiff’s ease showed that he was a consulting engineer, specializing in the field of heating, ventilating and air conditioning. While he was employed by the defendant, he received an offer from Purdue University for employment at a yearly salary, which would leave him free for three months to continue his practice; and while performing his duties at the university he would be permitted to carry on his private work so far as time permitted. He communicated this offer to the defendant, which promised, if he would refuse the Purdue offer and would purchase the home of defendant’s power superintendent, it would give him permanent employment. A demurrer was sustained in the trial court and the judgment affirmed by the Minnesota Supreme Court. That court said: “The words ‘permanent employment’ have a well-established meaning in the law. The general rule is well stated in 18 R. C. L. p. 509, Sec. 20: ‘In case the parties to a contract of service expressly agree that the employment shall be “permanent” the law implies, not that the engagement shall be continuous or for any definite period, but that the term being indefinite *1226the hiring is merely at will.’ ” Loc. cit. 197 Minn. 294, 266 N.W. 873, 874.

With reference to plaintiff’s contention that consideration passed from him to the defendant, the court said: “ ‘The effort of plaintiff to show an additional consideration passing from him to defendant was abortive since it shows that he merely abandoned other activities and interests to enter into the service of defendant' — a thing almost every desirable servant does upon entering a new service, but which, of course, cannot be regarded as constituting any additional consideration to the master’.” Loc. cit. 302 of 197 Minn. To the same effect is Arentz v. Morse Dry Dock & Repair Co., 249 N. Y. 439, 164 N.E. 342, 344, 62 A. L. R. 231.

Our own eases, while not entirely clear on the point, seem to uphold the authorities from other jurisdictions. Thus in Lewis v. Minnesota Mutual Life Insurance Co., 240 Iowa 1249, 37 N.W.2d 316, we stated and followed the general rule that in the absence of a consideration in addition to the services to be rendered, contracts for permanent employment are indefinite hirings, terminable at the will of either party. Loc. cit. 240 Iowa 1259, 1260, 37 N.W.2d 322; and we also said that “The giving up of the opportunity to take other employment cannot be held to be an additional consideration.” Skagerberg v. Blandin Paper Co., supra, is cited. Loe. cit. 240 Iowa 1260, 37 N.W.2d 322, 323. Although other matters were considered in the Lewis case, the holding and language referred to last above are pertinent.

II. In Faulkner v. Des Moines Drug Co., 117 Iowa 120, 90 N.W. 585, in which the plaintiff claimed a contract for employment “until mutually agreed void”, we cited with approval Lord v. Goldberg, supra, for the rule that “a contract for ‘permanent’ employment is construed to mean nothing more than that the employment is to continue indefinitely, and until one or the other of the parties desires for some good reason to sever the relation.” Loc. cit. 117 Iowa 122, 90 N.W. 586. In the Faulkner ease a demurrer to the petition was sustained by the trial court, and its judgment affirmed by us. Much of the discussion pertained to the indefiniteness of the contract, as to amount of prospective earnings, and the length of time the damages should be computed. *1227We said: “Or, if it be said that the profits earned before the breach of the contract furnish a basis for estimating* future returns, then for what length- of time shall they be computed ? Shall it be for one month, one year, ten years, or for the entire period of the plaintiff’s expectancy of life? Who can place any reasonable estimate upon the period which would probably elapse before the parties ‘mutually agree’ that the contract between them shall be considered ‘void ?’ ” Loe. cit. 117 Iowa 123, 90 N.W. 587. If we substitute for “mutually agree” the words “until you retire of your own choosing”, an equally uncertain happening, we have the identical case which we held insufficient in Faulkner v. Des Moines Drug Co., supra. The difficulty of delineating any definite claim for damages is pointed up by the prayer of the plaintiff’s petition, which we have referred to above. How would the trier of the facts have any guide as to how many years it might be “until he chose to retire”; ■ or how much his loss might be mitigated by other employment which he might secure? It might be contended that the “reasonable time” rule should be adopted as we did in the case of the agency contract involved in Des Moines Blue Ribbon Distributors v. Drew-rys Limited, supra. But in the first place, the plaintiff neither pleads nor contends for such a measure of damages; and in the second, there was adequate consideration for the agreement in the Blue Ribbon ease, while the general rule which we have discussed and followed in Division I demonstrates that such consideration is lacking here.

III. There is a class of cases in which sufficient consideration to uphold a contract for permanent, or life, employment, or employment so long as the employee chooses, has been found. These are eases in which the servant has been found to have paid something for the promise of the employment, in addition to his agreement to render services. A majority of them are cases in which the employer, faced with a claim for damages, agreed to give the claimant permanent employment in consideration of the release of his. claim. Many of these cases are collated in Chesapeake & Potomac Tel. Co. v. Murray, supra, pages 873 and 874 of 84 A.2d. A case involving a different but also valid consideration is Carnig v. Carr, 167 Mass. 544, 46 N.E. 117, 35 L. R. A.

*1228512, 57 Am. St. Rep. 488. The factual situation there was that the plaintiff; had been engaged in a competing business with the defendant, and had accepted permanent employment which involved the abandonment of his own enterprise. The defendant thereby received the benefit of removal of competition. So in the Iowa case of Thompson v. Miller, 251 Iowa 324, 100 N.W.2d 410; the contract involved more than a mere hiring. The inapplicability of the ease to the present situation is shown by this quotation: “In this case more is involved than mere services. Plaintiff paid half of the advertising and sales costs and all of his traveling expenses.” Loe. cit. 251 Iowa 327, 100 N.W.2d 412. We also said: “On the other hand, the hitch pin enterprise was new. It was plaintiff’s idea and uncertain as to its future. The parties may have considered it in the nature of a joint adventure into which plaintiff ivas putting cash as well as his services.” Loe. cit. 251 Iowa 328, 100 N.W.2d 412.

IV. Two cases cited and relied upon by the plaintiff contain language in apparent opposition to the general rule set forth in Divisions I and II above. These are Littell v. Evening Star Newspaper Co., 73 App. D. C. 409, 120 F.2d 36, and Eggers v. Armour & Co. of Delaware, C. C. A., 8th Cir., 129 F.2d 729. They are not in line Avith the great majority of authority, or Avith our own expressions in Lewis v. Minnesota Mutual Life Insurance Company and Faulkner v. Des Moines Drug Company, both supra. We think the real basis for the majority rule is that there is in fact no binding contract for life employment, when the employee has not agreed to it; that is, when he is free to abandon it at anytime. So in the instant case, the plaintiff was bound only so long as he chose to work. It does not help to say that a contract for life employment, or permanent employment, may be binding if it is fully agreed upon, even though the only consideration furnished by the employee is his agreement to serve. The fact is he has not agreed to serve for life, or permanently; but only so long as he does not elect to “retire of his oavu choosing.” What the rule might b.e if he had bound himself to work for life, or so long as he was able, we have no occasion to determine. These observations go to the lack of mutuality and would not be important if there Avas other *1229consideration. Many difficulties would arise even if such a contract had been made and upheld, in the way of determining the damages because of uncertainty of type of employment, or rate of pay, or how much his loss might be mitigated, in the event of wrongful discharge, by other employment which he might find. But we have no occasion to go further into those questions here. The ease is ruled by the authorities cited in Divisions I and II and by the legal principles there set forth. The trial court correctly granted the defendant’s motion for a peremptory verdict. — Affirmed.

All Justices concur except Hays, J., not sitting, and Garfield, C. J., who dissents.

*538CIRILLO, President Judge:

This is an appeal from a grant of summary judgment by the Court of Common Pleas of Allegheny County. We reverse and remand.

Appellant, William Greene began working for Grant Building, Inc. in 1959. Greene allegedly agreed to work at a pay rate below union scale in exchange for a promise that Grant would employ him “for life”. In 1975, appellee Oliver Realty, Inc. took over management of Grant Building but Oliver’s president assured former Grant employees that existing employment contracts would be honored. During that same year Greene explained the terms of his agreement to an Oliver Realty supervisor. The supervisor stated that he would look into the matter but never got back to Greene. The trial court found that Oliver had impliedly adopted the oral contract between Greene and Grant Building. In 1983, Greene was laid off and he brought this action for breach of contract. The trial court ruled that under Pennsylvania law a contract “for life” is a contract at will. The court also held that a contract at will may become a contract for a reasonable time if it is supported by sufficient additional consideration other than the employee’s services. The court stated that there was no such consideration in this case. It found that Greene worked for subunion wages in order to avoid layoff not in exchange for lifetime employment. It also held that even if sufficient additional consideration was present, the period of 1975 to 1982 constituted a reasonable time. Therefore, there was no breach of the contract and the court granted Oliver’s motion for summary judgment.

Appellant presents three issues for our review: (1) whether the issue of sufficient additional consideration should go to the jury; (2) whether the issue of “reasonable” period of time should go to the jury; and (3) whether Greene is entitled to reach the jury on the issue of equitable estoppel. Because of our disposition of this matter it is unnecessary for us to consider these issues separately.

*539Contemporary contract law generally provides that a contract is enforceable when the parties reach mutual agreement, exchange consideration and have outlined the terms of their bargain with sufficient clarity. See Com. Dept. of Transp. v. First Penna. Bank, 77 Pa.Commw. 551, 466 A.2d 753 (1983). An agreement is sufficiently definite if the parties intended to make a contract and there is a reasonably certain basis upon which a court can provide an appropriate remedy. See Linnet v. Hitchcock, 324 Pa.Super. 209, 214, 471 A.2d 537, 540 (1984).

If an essential term is left out of the agreement, the law will not invalidate the contract but will include a reasonable term. For instance, if the parties do not specify price, a court will impose a reasonable price which will usually be the item’s market value. See Murray, Murray on Contracts 48 (1974). See also Kuss Mach. Tool & Die Co. v. El-Tronics Inc., 393 Pa. 353, 143 A.2d 38 (1958). However, if the parties include the term but have expressed their intention ambiguously, the court will not impose a reasonable term and the contract may fail for indefiniteness. Id. 143 A.2d at 40. A court will not attempt to fix contractual terms which are inconsistent with the intent of the parties. That is because the paramount goal of contractual interpretation is to ascertain and give effect to the intent of the parties. See Burns Mfg. Co., Inc. v. Boehm, 467 Pa. 307, 313, 356 A.2d 763, 766 (1976). When the language of a written contract is clear and unequivocal, its meaning must be determined by its contents alone. Mears, Inc. v. National Basic Sensors, 337 Pa.Super. 284, 289, 486 A.2d 1335, 1338 (1984). Only if the words used are ambiguous may a court examine the surrounding circumstances to ascertain the intent of the parties. Kennedy v. Erkman, 389 Pa. 651, 655, 133 A.2d 550, 552 (1957). However, in cases involving oral contracts the complete agreement is not recorded. Therefore, in that situation, courts must always examine the surrounding circumstances to determine the parties intent. Westinghouse Elec. Co. v. Murphy, Inc., 425 Pa. 166, 171-72, 228 A.2d 656, 659 (1967). Because *540courts wish to effectuate the parties intentions, they may enforce an indefinite contract if its terms have become definite as the result of partial performance. One or both parties may perform in such a way as to make definite that which was previously unclear. Murray, Contracts at 51-52. See also Com. Dept. of Transp. v. Mosites Const. Co., 90 Pa.Commw. 33, 494 A.2d 41 (1985).

Traditional contract law distinguished between contracts involving two promises which were called bilateral and contracts involving only one promise which were called unilateral. Murray, Contracts at 9. A bilateral contract is created when one party promises to do or forbear from doing something in exchange for the other party’s promise to do or forbear from doing something else. In a unilateral contract there is only one promise. It is formed when one party makes a promise in exchange for the other person’s act or performance. Id. at 10. Mutuality of obligation means that both parties are under an obligation to perform their promises. It is often stated that a contract is unenforceable if there is no such mutuality but this principle is inapplicable to unilateral contracts. See Darlington v. General Elec., 350 Pa.Super. 183, 203, 205, 504 A.2d 306, 316, 317 (1986). If A promises B $100 if B walks across the Brooklyn Bridge, a unilateral contract will be formed if B does as A requests. It is a unilateral contract because it consists of a promise in exchange for a performance. However, the contract is not formed until B walks across the bridge. At that time, A owes B $100 even though B no longer has any obligation to A. A unilateral contract is formed by the very act which constitutes the offeree’s performance. Therefore, mutuality of obligation will never exist in such a situation. By the time the contract is formed, only the offeror will remain obligated. The offeree will already have performed. This is why the Restatement provides that: “If the requirement of consideration is met, there is no additional requirement of ... (c) ‘mutuality of obligation.’ ” Restatement of Contracts (Second) § 79 (1981).

*541The other problem with mutuality of obligation is that the doctrine is often confused and misinterpreted even in cases concerning bilateral contracts. Courts sometimes refuse to enforce a single promise made in exchange for several promises. See Perritt, Employee Dismissal Law and Practice, 47 (1984). They require that each promise must be supported by a separate consideration. This is usually done in the name of mutuality of obligation. However, if person A promises to do something in exchange for person B’s promise to do three things, there is mutuality of obligation. A is obligated to do as he promised, as is B, though B’s obligation entails three promises. Both parties are obligated, so mutuality of obligation is present. However, B’s obligation appears greater than A’s. Courts sometimes decline to force B to perform because of this difference in obligation. These courts are implicitly requiring that both parties to a contract must have concurrent or equivalent obligations. If one party is “more” obligated than another, the contract fails. This result is incorrect because consideration may be any bargained for exchange. Com. Dept. of Transp. v. First National Bank, N.A., 77 Pa.Commw. 551, 466 A.2d 753 (1983). If B desired A’s promise sufficiently to make three promises of his own, there is no reason why the law should not enforce the arrangement. As in any other contract, each party bargained for what he wanted. Modern contract law recognizes that, “If the requirement of consideration is met, there is no additional requirement of ... (b) equivalence in the values exchanged....” Restatement of Contracts (Second) § 79 (1981). It then follows logically that, “[s]ince consideration is not required to be adequate in value (see § 79), two or more promises may be binding even though made for the price of one.” Id. at § 80 comment a. See Thomas v. Thomas Flexible Coupling Co., 353 Pa. 591, 598, 46 A.2d 212, 216 (1946). Those courts which invalidated agreements like the one described above did so in the name of mutuality of obligation. But, as noted above, mutuality of obligation is present in this type of situation and equivalency of obligation is not required in contract *542law. See Restatement § 79. Therefore, modern contract law recognizes such agreements as valid and enforceable.

However, there is one area of contract law which is strikingly idiosyncratic. That is the law of employment contracts. It has developed contrary to all of the standard, modern contract principles discussed above. If the parties to an employment contract do not specify the duration of the contract, a court will not imply a reasonable duration. The contract is considered terminable at will. If the parties contract for “lifetime” employment, many courts will refuse to enforce their bargain even if their intentions are clear. Even if the agreement is oral, courts refuse to consider the surrounding circumstances. Though mutuality of obligation is a discredited notion, it is often required in the employment context, even when the employment agreement is a unilateral contract. Also, courts routinely refuse to enforce employment contracts if they entail a single promise made in exchange for several promises. In reaching these results, courts rely on anachronistic theories which they would never apply in other fields of contract law. The strong resistance of employment law to modern contract doctrine is a testament to the influence of a uniquely American legal tradition: the at-will presumption.

A thorough analysis of this area of law demonstrates the continuing importance of this presumption. It is far from the antiquated and outmoded principle that its critics claim. The presumption is attacked because its theoretical underpinnings are inadequately understood. The same is true of our court system’s reluctance to enforce lifetime employment agreements. The reasons given for this reluctance are so obviously insufficient that observers have concluded that there are no good reasons for the policy and such contracts should be readily enforceable. We agree that current rules of construction are too artificial. However, we also believe that there are good reasons why courts should be very careful before they enforce a lifetime employment contract.

*543Despite the principle of contractual interpretation that courts must ascertain and give effect to the parties’ intent, employment law creates a presumption which may be contrary to that intent. An employment agreement is presumptively terminable at will by either party. The employee may leave the job for any or no reason or the employer may terminate the employee for any cause or no cause. Darlington v. General Elec., 350 Pa.Super. 183, 188, 504 A.2d 306, 309 (1986). The party claiming that an agreement is for a definite period has the burden of proving that fact. Geary v. United States Steel Corp., 456 Pa. 171, 175, 319 A.2d 174, 176 (1974). This requirement is satisfied by clear proof that the parties contracted for a specific duration. See Maloney v. Madrid Motor Corp., 385 Pa. 224, 228-29, 122 A.2d 694, 696 (1956). When it is proven that the contract specified a definite period, the employee may not be terminated during that period unless the employer has “just cause”. Darlington, 350 Pa.Super. at 204, 504 A.2d at 316. However, the presumption is strong enough that it usually is not rebutted by an agreement which specifies that it is for “permanent” or “lifetime” employment. For various reasons, the intent of the parties is often ignored in such a situation in deference to the at-will presumption. But, if such contracts was enforceable, the employee could not be terminated without cause.

A presumption is a procedural device which shifts the burden of persuasion. Bixler v. Hoverter, 89 Pa.Commw. 88, 91, 491 A.2d 958, 959, (1985). A presumption of law compels the fact finder to reach a particular conclusion in the absence of evidence to the contrary. Stine v. Borst, 205 Pa.Super. 46, 53, 205 A.2d 650, 654, (1964). Presumptions arise over the course of time through experience and common observation. When experience shows that a connection exists between things so that one usually follows the other, this connection may become the foundation for a legal presumption. Watkins v. Prudential Ins. Co., 315 Pa. 497, 504, 173 A. 644 (1934). A legal *544presumption may also be based upon procedural expediency or public policy. See Chadbourn & Wigmore, Wigmore on Evidence 287-91 (1981).

The at-will presumption is based on an uneasy marriage of procedure, policy and experience. Our review of the relevant cases and literature reveals that there are five policies underlying the presumption: (1) The policy of freedom of contract; (2) the need for mutuality of obligation; (3) common experience that it usually effectuates the intent of the parties; (4) as a procedural protection against merit-less but vexatious lawsuits; and (5) fairness and equity.

English courts traditionally held that a contract of employment for an indefinite term was presumed to be a contract for one year. Darlington, 350 Pa.Super. at 189-90, 504 A.2d at 309. However, American courts of the late 1800’s rejected this view. These courts adopted the doctrine of freedom of contract. This principle implies that the terms of an economic relationship should be determined entirely by the parties. Therefore, no presumptions affecting the relationship should be imposed by law. It may now seem ironic, but the doctrine of at-will employment was originally based upon a rejection of artificial presumptions. See Perritt, Employee Law at 5.

However, in the late 1800’s and early 1900's, “commerce was King [and] laws were tailored to facilitate business.... Thus, laws ... largely left business decisions to businessmen.” Darlington, 350 Pa.Superior Ct. at 189-90, 504 A.2d at 309. As one commentator has written, “the prevailing economic theories of the day exhalted the role of market forces....” Perritt, Employee Law at 4. The at-will rule flourished in this atmosphere. It allowed businessmen unfettered discretion in hiring and firing. Employees were encouraged to sell their labor to the highest bidder and employers were free to hire and fire as they saw fit. It was believed that this state of affairs resulted in the greatest maximization of wealth to society. The doctrine was so appropriate for the pro-business temper of the times that it was soon accepted as a legal presumption by the vast *545majority of American courts. Its basis was originally freedom of contract, but this was soon confused and contorted so that the rule’s true foundation became freedom for employers to manage their businesses as they wished. Id. at 4-7.

By the early 1900’s, the at-will presumption was as inflexible and artificial as the one year rule it had replaced. The presumption was originally rebuttable if the employee produced evidence sufficient to establish an implied-in-fact contract. But it gradually developed into a substantive limitation whereby the employment relationship was conclusively at-will. Courts refused to enforce informal employment contracts even though such a refusal might be contrary to the parties’ actual intent. Perritt, Employee Law at 6. As previously discussed, freedom of contract implies that the parties are free to determine the terms of their relationship. The at-will presumption was supposedly based upon this principle. Yet, courts formalistically enforced the rule, allowing it to become a substantive limitation upon the parties’ freedom to contract. The presumption actually developed contrary to the very principle upon which it was based.

Therefore, the policy of freedom of contract encourages courts to effectuate the intent of the parties. To the extent that legal rules stymie this intent, they also obstruct freedom of contract. The right of competent adults to contract is the lifeblood of our free enterprise system. Voluntary agreements are the foundation of our society’s freedom and prosperity. If two parties desire to contract “for life”, courts should be encouraged to enforce their agreement. Of course, the at-will presumption may still be a sound legal rule. It is only when it is allowed to conclusively foreclose proof of the parties intent that it becomes an obstacle to freedom of contract. Also, the rule is supported by valid procedural, practical and equitable concerns.

One rationale for the rule which is illogical and undeserving of perpetuation is that of mutuality of obligation. Courts have often held that mutuality of obligation is *546lacking in the employment context, particularly in regard to contracts for permanent employment. See, e.g., Alabama Mills, Inc. v. Smith, 237 Ala. 296, 186 So. 699 (1939); Pitcher v. United Oil & Gas Syndicate, Inc., 174 La. 66, 139 So. 760 (1932); Roxana Petroleum Co. v. Rice, 109 Okl. 161, 235 P. 502 (1924); Louisville & N.R. Co. v. Cox, 145 Ky. 667, 141 S.W. 389 (1911). Several reasons have been proffered for this conclusion: (1) there is no consideration for the employer’s promise; (2) only the employer is obligated; and (3) the employer is obligated for a longer period than the employee. None of these justifications has merit.

In order for a promise to be binding, it must usually be made in exchange for consideration. However, consideration may be any bargained for benefit or detriment. Estate of Beck, 489 Pa. 276, 282, 414 A.2d 65, 68 (1980). An employer is free to promise lifetime employment to someone in exchange for that person coming to work for the employer. Once that person accepts and starts work, the employer has received exactly what he bargained for. The employee has performed the desired act. That act is the consideration for the employer’s promise and their agreement is a unilateral contract. It is irrelevant that the employee’s services are also consideration for his salary. Modern contract law recognizes that consideration may be a single act exchanged for several promises. Richter v. Mozenter, 356 Pa. 650, 654, 53 A.2d 76, 78 (1947). See Restatement Contracts (Second) § 79 (1981). Therefore, an employee is free to sell his services in exchange for wages and a promise of lifetime employment.

Once the employee begins work, the employer may be the only party obligated, but that is standard in situations involving a unilateral contract. The promisor has requested a performance as the price of his promise. Once he receives that performance, it would defy all notions of equity to allow him to avoid his obligation by claiming that the promisee is no longer obligated. He is no longer obligated because he has already performed the agreed upon acts. As previously discussed, this is the reason that mutuality of *547obligation is inapplicable to unilateral contracts. See Restatement § 79.

The employer and employee need not be obligated for coextensive periods of time. The law does not require equivalency of consideration. Therefore, the employee may be bound for one period of time though the employer is bound for much longer.

The at-will presumption, like most other legal presumptions, is also based upon common experience. In the vast majority of employer-employee relationships, both sides are silent about the expected duration of the employment agreement. The employee usually feels free to leave and take another job if it presents a more desireable opportunity. Similarly, the employer generally feels free to discharge the employee if he no longer wants his services. The at-will presumption is simply a legal recognition of the parties’ normal expectations. In the vast majority of cases, it is consistent with the parties' intent. Therefore, it is procedurally expedient that the law recognizes it as a presumption. It is a waste of time and resources to require parties to re-prove time and again that which experience shows is normally true. It is much more efficient to recognize the fact in question as true and require the parties to demonstrate if exceptional circumstances are present. However, the court must allow the parties to demonstrate whether those exceptional circumstances do exist. Courts must not allow the at-will presumption to foreclose such proof. Equity demands that the parties to a contract receive that which they intended to exchange. See Burns, 467 Pa. at 313, 356 A.2d at 766 (“Rules of Construction serve the legitimate purpose of aiding courts in their quest to ascertain and give effect to the intention of the parties. . . . They are not meant to be applied as a substitute for that quest.”). If courts allow the at-will rule to become a conclusive presumption then the parties are prevented from proving their actual intent. Courts must guard against this result. A presumption is a procedural tool to aid courts in carrying out their task. That task is doing justice. It is a terrible distortion of priorities to elevate concerns of efficiency over those of *548equity. If at all possible, a court must effectuate the intent of the parties. Justice must always remain paramount.

The at-will presumption also provides another important procedural protection. If there were no such rule, any dismissed employee could file suit based on an alleged oral contract. The ensuing lawsuit would then hinge solely on credibility. We note that a jury is much more likely to be composed of employees as opposed to employers. We hope that it does not exhibit too cynical a view of humanity for us to be concerned that this might affect more than an occasional verdict. The law is replete with procedural rules designed to guard against the danger of prejudicial jury verdicts. The at-will presumption is such a rule. However, the presumption can be rebutted by clear evidence that the parties intended a contrary result. This is a sufficient safeguard. It balances the need to protect against prejudicial verdicts with the legal system’s obligation to enforce the individual parties expectations. However, the danger of prejudicial verdicts is sufficiently strong to be of particular concern if an alleged “lifetime” contract is at issue. A contract for life is a heavy burden to impose upon an employer. Courts should be careful that when such a burden is imposed it is because that is what was contracted for and not because the jury was impassioned and sought to wreak vengeance. This danger is one of the reasons courts refuse to enforce such a contract if the only proof of its existence is that the parties exchanged promises. The parties may have used the words “permanently” or “for life” in an off-hand manner. These words are much too ambiguous to provide the sole basis for a jury’s imposition of such a tremendous obligation. Courts must look to the surrounding circumstances to determine the parties intent. Of course, that is standard in cases involving oral contracts. Westinghouse, 425 Pa. at 171, 228 A.2d at 659.

Another policy supporting continued recognition of the at-will presumption is that of simple fairness. This may surprise those commentators who complain that the rule is “antiquated” and “barbaric” because it leaves the “poor” *549employee without legal protection. See Decker, At-Will Employment in Pennsylvania—A Proposal For Its Abolition and Statutory Regulation, 87 Dickinson L.Rev. 477 (1983). But, a cursory analysis demonstrates that the situation is not as one-sided as it may at first appear.

We have already discussed the situation where an employer offers an employee employment for a definite period in exchange for the employee merely agreeing to take the job. The employer is bound to provide a job for the whole of the agreed upon period. But, the employee is free to leave the job at any time. However, a scenario which is much more likely to occur is where the employer and employee both agree that the employment relation is to last for a definite period. Both parties are then bound for that period. If the employer fires the employee, he can sue his former boss and recover damages. However, if the employee quits before the agreed upon period of time has expired, what recourse is available to the employer? If he sues the employee, he will have difficulty proving damages. He will need to show that the loss of this one employee caused his business to lose money. Even if the employer wins a judgment he would then have to enforce it. The old adage that you can not get blood from a stone is particularly apt in this situation. Most individuals do not have the resources to satisfy anything but the most meager judgment. Therefore, an aggrieved employee will probably have a legal remedy, but an aggrieved employer will not. This is a very inequitable result. A legal system loses all legitimacy if it deigns to treat one group more favorably than another. The law cannot pick and choose its favorites.

The at-will presumption is a partial response to this quandary. Absent the presumption, the law is naturally prone to favor the interests of the employee. The presumption may make it slightly more difficult for the employee to recover if he brings an action. But this merely serves as a partial redress of the unfair situation which would otherwise occur.

*550A lifetime contract is a tremendous obligation to impose upon an employer. Yet, it is very difficult to enforce any employment agreement against an employee. It is unfair to place an odious burden upon one party if the other party’s actual obligation is negligible. Thus, fairness also dictates that courts should proceed with caution when dealing with alleged lifetime contracts.

Therefore, our review of the applicable policies demonstrates that the at-will presumption remains a sound legal rule. It provides a sensible balance of the relevant concerns. Most of the rule’s underlying premises remain valid. But, courts must remain flexible and not allow the presumption to foreclose proof of the parties’ intent. Though the rule is a necessary procedural safeguard, a court’s primary task is to ascertain and enforce that intent. The presumption itself grew out of the doctrine of freedom of contract. This principle holds that the terms of the economic relationship should be determined by the parties and not by artificial rules of legal construction. If the presumption is used to frustrate the desires of the contracting parties, the rule is robbed of its logic and validity. Our review also shows that lifetime employment contracts are a tremendous burden. Courts should be very careful before enforcing them. However, if the intent of the parties is clear, then so is a court’s obligation. It must enforce that intent.

However, in cases involving lifetime employment contracts, many courts ignore the parties’ desires. In some jurisdictions, lifetime employment contracts are terminable at will unless these is proof of “sufficient additional consideration.” See cases collected Annot., 60 A.L.R.3d 226, 237-40 (1974). See also Darlington, 350 Pa.Super. at 199-200, 504 A.2d at 314. The additional consideration which is required is something other than the employee’s day to day services. It could be leaving another job, passing up a better opportunity or declining to sue, etc.

These courts require that “sufficient” additional consideration be present or they will not find the at-will presumption overcome in a case involving a permanent employment *551contract. Courts require additional consideration because they find that permanent employment contracts are otherwise lacking in mutuality of obligation. In these jurisdictions, the presumption will not be rebutted even by strong, independent evidence that the parties intended the contract to last for life. Some courts hold that such agreements are too vague to be enforceable. See 60 A.L.R.3rd 226, 304-15 (1974). Unfortunately, they fail to explain how additional consideration clarifies matters.

Therefore, courts refuse to enforce lifetime employment agreements based on reasons of lack of mutuality and indefiniteness. This result has often been criticized as inconsistent and illogical. See Perritt, Employee Law at 151. We agree.

Under modern contract doctrine, an agreement does not fail for vagueness if the parties intended to form a contract and there is a reasonably certain basis for giving an appropriate remedy. Linnet, 324 Pa.Super. at 214, 471 A.2d at 540. The at-will presumption can only be overcome by clear evidence that the parties intended to contract for a definite period. See Maloney, 385 Pa. 224, 229, 122 A.2d 694, 696 (1956). Therefore, a litigant will only be able to reach the jury if he can clearly show that he and the defendant intended to form a contract. It is also easy enough for a court to fashion a remedy. Some courts have disagreed, questioning the details of such agreements. What is the rate of pay? The hours? The working conditions? These are some of the questions courts have posited. See Green v. Medford Knitwear Mills, 408 F.Supp. 577 (E.D.Pa.1976). However, they are easily answered. The employee will have partially performed prior to the alleged breach. An indefinite agreement may become definite by virtue of partial performance. See Murray, Contracts at 51-52. The employee’s rate of pay, hours and working conditions will already have been determined. The partial performance which has already taken place provides the basis for the court’s remedy. Because, lifetime employment contracts satisfy the Linnet court’s two-part test they should not fail for indefiniteness.

*552Mutuality of obligation is a thoroughly discredited notion. As previously discussed, it is inapplicable to unilateral contracts. Any rule which purportedly derives its legitimacy from this principle is a rule deserving of a rapid interment.

However, other courts utilize a more flexible approach. These courts view the presence of such consideration as proof that the parties intended the employment relation to be more binding than the standard terminable at will agreement. These courts view additional consideration as a factor to consider in determining the parties intent but not as a rigid requirement. Under this view, the at-will presumption may theoretically be overcome by clear evidence even if that evidence does not include proof of additional consideration. However, such proof is helpful because it is persuasive in rebutting the presumption. See Eilen v. Tappin’s Inc., 16 N.J.Super. 53, 83 A.2d 817 (1951). As the Darlington court explained:

“the term ‘consideration’ is not used here as it is in the usual contractual context to signify a validation device. The term is used, rather, more as an interpretation device. When ‘sufficient additional consideration’ is present, courts infer that the parties intended that the contract will not be terminable at-will.”

Darlington, 350 Pa.Super. at 199-200, 504 A.2d at 314.

However, the exchange of such consideration is only one of many potential factors which a court should consider. In Darlington, the court also quoted our Supreme Court’s holding in Price v. Confair, 366 Pa. 538, 79 A.2d 224 (1951).

The court stated:

“[I]t is the intention of the parties which is the ultimate guide, and in order to ascertain that intention, the court may take into consideration the surrounding circumstances, the situation of the parties, the objects they apparently have in view, and the nature of the subject matter of the agreement.”

Id., 366 Pa. at 542, 79 A.2d at 226.

Under this more flexible approach, additional consideration is merely considered indicative of the parties’ intent. If *553the parties exchanged “extra” consideration, it is logical that they expected their relationship to be more lasting than the usual employment agreement. However, it is very possible that the parties so intended but did not exchange additional consideration. The surrounding circumstances and the parties’ own expressions may still provide clear evidence of that intent. If so, courts must enforce the parties’ desired bargain. Otherwise, they are using an evidentiary rule, the at-will presumption, to defeat the parties’ intent. As already discussed, this is directly contrary to the doctrine of freedom of contract.

Pennsylvania courts have traditionally followed the flexible approach, recognizing that the paramount concern is the intention of the parties.

In Lubrecht v. Laurel Stripping Company, 387 Pa. 393, 127 A.2d 687 (1956), the Court repeated the maxim that an employment contract is presumptively terminable at will. The court stated that this presumption may be overcome by proof of the parties’ intent based on the “surrounding circumstances.” Id., 387 Pa. at 396, 127 A.2d at 690. The Court made no mention of additional consideration.

In Lightcap v. Keaggy, 128 Pa.Super. 348, 194 A. 347 (1937), the court refused to enforce an agreement for lifetime employment because of indefiniteness. The court stated that it was unable to ascertain the parties’ intent with sufficient clarity. Id., 128 Pa.Superior Ct. at 356, 194 A. at 350. The plaintiff had been promised “suitable employment” but the court questioned “[w]hat is suitable employment?” Id. The court also questioned the scale of pay, hours of work and the working conditions since none of these were specified. Because these details were not spelled out, the court refused to enforce the agreement. However, modern contract doctrine is very different from that of 1937. Vague and indefinite agreements are routinely enforced as long as courts are able to supply “reasonable” terms. Courts are more willing to supply such terms if the parties have already partially performed their obligations. If the Lightcap case were construed by a modern *554court, it would look to the parties’ practice prior to the alleged breach. That practice would supply the rate of pay, hours of work and working conditions. Although the Lightcap court refused to enforce a contract for lifetime employment, its refusal is of little precedential value because the result was based on principles of contract law which are now outdated. The court did state that use of the word “permanent” is not in and of itself sufficiently clear to rebut the presumption. We have no quarrel with this conclusion. Proof of an agreement to employ someone permanently or “for life” is not clear evidence. However, when viewed in the context of the surrounding circumstances, such expressions may rise to the requisite level of clarity.

In Lucacher v. Kerson, 158 Pa.Super. 437, 45 A.2d 245 (1946), this court recognized that very same principle. The court held that a contract for permanent employment is indefinite but the surrounding circumstances may demonstrate that it was intended to be for life. If so, it is enforceable. Additional consideration is one of the factors to consider when determining this intent. However, the court specifically noted that it is not the only factor of importance. The court stated that the absence or presence of additional consideration must be contemplated as well as “the other circumstances surrounding the making of the contract....” Id., 158 Pa.Superior Ct. at 443, 45 A.2d at 248.

This same principle was recognized in the recent case of Murphy v. Publicker Industries, Inc., 357 Pa.Super. 409, 516 A.2d 47 (1986). A panel of this court, per Judge Beck, held that lifetime employment contracts are enforceable. The court ruled that something more than the mere agreement itself is necessary to rebut the at-will presumption in such a case. The court stated that “one exception” to the rule is when additional consideration is exchanged. 357 Pa.Superior Ct. at 418, 516 A.2d at 52. But, the court also held “that an employee can establish rights beyond at-will employment by means other than the additional considera*555tion rule.” Id., 357 Pa.Superior Ct. at 419, 516 A.2d at 52. Judge Beck stated that courts must focus on the circumstances surrounding the agreement and attempt to glean the parties’ intent from those circumstances.

We agree with Judge Beck’s careful reasoning. The at-will presumption may only be rebutted by clear evidence that the parties contracted for a definite period. See Maloney, 385 Pa. at 229, 122 A.2d at 696. A contract for lifetime employment is a heavy burden to place upon an employer’s shoulders. Because it constitutes such a tremendous obligation, courts must require evidence beyond mere proof of the parties’ agreement. A promise of permanent or lifetime employment may be nothing more than a casual aside. Or, it may be purely aspirational. The employer may be expressing his hope that a valued employee will stay with him forever. However, he may not have intended to create a binding agreement. These dangers are sufficiently real that courts must look to the circumstances surrounding the parties’ agreement. Only when those circumstances demonstrate the parties’ intent by clear evidence should a court enforce a lifetime employment contract. The presence of additional consideration is only a single factor, albeit an important one, which a court must consider to ascertain that intent. When the court is certain of the parties’ intent, it must enforce that intent, irrespective of whether additional consideration is present. If a court fails to effectuate the parties’ intent, it violates the canons of contract law as well as the very policies upon which the doctrine of at-will employment is based.

In the instant case, Oliver Realty impliedly adopted Grant Building’s promise to Greene of lifetime employment. In exchange for that promise, Greene alleges that he worked for twenty-four years at a pay rate below union scale. A trial court must allow an issue to go to the jury unless it is so clear that reasonable minds could not possibly differ over its resolution. Correll v. Werner, 293 Pa.Super. 88, 90, 437 A.2d 1004, 1005 (1981). The court concluded that Greene worked at sub-union rates in ex*556change for a promise that he would not be laid off and not in exchange for a lifetime contract. This is an inappropriate conclusion. This is a factual issue which must be submitted to a jury. Greene’s belief that he had been promised lifetime employment was sufficiently strong that he explained his position to a supervisor after Oliver took over Grant Building. The court must allow the jury to consider Greene’s alleged “additional consideration” as well as all the circumstances surrounding the agreement. A jury might reasonably interpret the above cited facts so as to conclude that Greene has clearly rebutted the at-will presumption.

The trial court also ruled that even if Greene successfully rebutted the presumption, he was only entitled to employment for a “reasonable” time which he had already received. This conclusion is incorrect. If the jury finds that Greene and Oliver Realty contracted for lifetime employment, such an agreement is enforceable. Darlington suggests that the presumption may be rebutted by evidence that the parties did not intend their relationship to be at-will. However, the court may be unable to determine the exact period for which the parties did intend to contract. In such a situation, the court may infer that the agreement is for a “reasonable” time. However, this principle is only applicable to the case before us if the jury finds that Greene’s employment relation with Oliver was not at-will but was also not “for life.” Under the authority of Darlington, the trial court may then interpret the agreement as being for a “reasonable time.” We refuse to make an inflexible rule that all enforceable promises of lifetime employment constitute contracts which are to last for a “reasonable period.” As we have repeatedly stressed, the paramount goal of contractual interpretation is to effectuate the parties’ intent. Piling presumption upon presumption results in that intent being obscured by a procedural morass. That is not the way for courts to achieve justice.

We do not view our decision today as a change in the law of Pennsylvania. Rather, we have attempted to summarize *557and synthesize some of the law applicable to employment contracts. We believe that Pennsylvania caselaw on this subject may be superficially confusing, however, upon careful analysis it is apparent that the principles underlying the cases are consistent.

Based on the above analysis, we reverse and remand for further proceedings consistent with this opinion.

POPOVICH, J., concurs in result.

Wright, J.

NATURE OF CASE

Julie Goff-Hamel brought this action against Obstetricians & Gynecologists, P.C. (Obstetricians), seeking damages for breach of an alleged oral employment contract or, in the alternative, damages for detrimental reliance on a promise of employment. The trial court granted summary judgment in favor of Obstetricians, and Goff-Hamel appeals.

SCOPE OF REVIEW

In reviewing a summary judgment, an appellate court views the evidence in a light most favorable to the party against whom the judgment is granted and gives such party the benefit of all reasonable inferences deducible from the evidence. Foreman v. AS Mid-America, 255 Neb. 323, 586 N.W.2d 290 (1998).

In reviewing a question of law, an appellate court reaches a conclusion independent of the lower court’s ruling. Hoiengs v. County of Adams, 254 Neb. 64, 574 N.W.2d 498 (1998).

FACTS

Goff-Hamel worked for Hastings Family Planning for 11 years. Prior to leaving Hastings Family Planning, Goff-Hamel was earning $24,000 plus the following benefits: 6 weeks’ paid maternity leave, 6 weeks’ vacation, 12 paid holidays, 12 sick days, an educational reimbursement, and medical and dental insurance coverage.

In July 1993, Goff-Hamel met with representatives of Obstetricians regarding the possibility of employment. Present at the meeting were Janet Quackenbush, the office manager; Dr. *21George Adam, a part owner of Obstetricians; and Larry Draper, a consultant of Obstetricians involved in personnel decisions. Adam had approached Goff-Hamel in June 1993 about working for him as a patient relations and outreach coordinator at Obstetricians. Goff-Hamel initially declined the offer, explaining that she had made commitments to do some training in the fall and to hire and help train a new bookkeeper. Adam spoke to Goff-Hamel approximately 1 month later, asking her to reconsider and whether she was ready to “jump ship and come work for him.” Goff-Hamel told Adam she would be interested in hearing some details, and an interview was set for July 27 at Adam’s office.

At the meeting, Adam represented to Goff-Hamel that the position would be full time and would start at a salary of $10 per hour and that she would be provided 2 weeks’ paid vacation, three or four paid holidays, uniforms, and an educational stipend. A retirement plan would start after the end of the second year, retroactive to the end of the first year. The job would not provide health insurance.

Goff-Hamel was offered a job with Obstetricians during the July 27, 1993, meeting, and she accepted the job offer at that time. She expressed concern that she be given time to finish some projects at Hastings Family Planning, and it was agreed that she would start her employment on October 4. Goff-Hamel gave notice to Hastings Family Planning in August, informing them that she would be resigning to take a job with Obstetricians.

Subsequently, Goff-Hamel went to Obstetricians’ office and was provided with uniforms for her job. She was given a copy of her schedule for the first week of work, but did not receive a copy of the employee handbook.

On October 3, 1993, Goff-Hamel was told by Draper that she should not report to work the next morning as had been planned. Draper told her that Janel Foote, the wife of a part owner of Obstetricians, Dr. Terry Foote, opposed the hiring of Goff-Hamel.

The trial court found that there were no facts in dispute and that Goff-Hamel had not turned down any other employment opportunities between July and October 1993. The court found that she had terminated her employment at Hastings Family *22Planning in reliance on an offer of employment from Obstetricians; however, the prospective employment agreement was not for a specific term of employment. The court noted that Goff-Hamel sought replacement employment, but was unable to obtain employment until April 1995, when she was employed part time at the rate of $11 per hour.

The trial court concluded that since Goff-Hamel was to be employed at will, her employment could be terminated at any time, including before she began working. The court concluded that under either contract law or promissory estoppel, Obstetricians was entitled to a judgment as a matter of law.

ASSIGNMENTS OF ERROR

Goff-Hamel asserts that the trial court erred in sustaining Obstetricians’ motion for summary judgment and in overruling her motion for summary judgment.

ANALYSIS

In sustaining Obstetricians’ motion for summary judgment, the trial court concluded as a matter of law that since GoffHamel’s employment could have been terminated after 1 day without Obstetricians incurring liability, logic dictated that her employment could also be terminated before it started without liability.

It is undisputed that on July 27, 1993, Obstetricians offered Goff-Hamel employment and that she accepted. The oral agreement did not specify that the employment was for a definite period. We have consistently held that when employment is not for a definite term and there are no contractual, statutory, or constitutional restrictions upon the right of discharge, an employer may lawfully discharge an employee whenever and for whatever cause it chooses. See, Myers v. Nebraska Equal Opp. Comm., 255 Neb. 156, 582 N.W.2d 362 (1998); Gillis v. City of Madison, 248 Neb. 873, 540 N.W.2d 114 (1995); Hamersky v. Nicholson Supply Co., 246 Neb. 156, 517 N.W.2d 382 (1994). Therefore, the trial court correctly determined as a matter of law that Goff-Hamel could not bring a claim for breach of an employment contract.

Goff-Hamel’s second cause of action was based upon promissory estoppel. “ ‘[T]he development of the law of *23promissory estoppel “is an attempt by the courts to keep remedies abreast of increased moral consciousness of honesty and fair representations in all business dealings.”’” Rosnick v. Dinsmore, 235 Neb. 738, 751, 457 N.W.2d 793, 801 (1990).

Promissory estoppel provides for damages as justice requires and does not attempt to provide the plaintiff damages based upon the benefit of the bargain. Id. It requires only that reliance be reasonable and foreseeable. It does not impose the requirement that the promise giving rise to the cause of action must be so comprehensive in scope as to meet the requirements of an offer that would ripen into a contract if accepted by the promisee. Hawkins Constr. Co. v. Reiman Corp., 245 Neb. 131, 511 N.W.2d 113 (1994); Rosnick v. Dinsmore, supra.

We have not specifically addressed whether promissory estoppel may be asserted as the basis for a cause, of action for detrimental reliance upon a promise of at-will employment. In Merrick v. Thomas, 246 Neb. 658, 522 N.W.2d 402 (1994), the employee was terminated from her job approximately 4 months after she had been hired. We determined that because the employee had worked for a time, the employer had kept his promise to employ the plaintiff and that promissory estoppel was not available. We did not consider whether a cause of action based upon promissory estoppel could be stated by a prospective at-will employee who had been induced to leave previous gainful employment based upon the promise of other employment, but who did not commence employment at the new job.

Other jurisdictions which have addressed the question of whether a cause of action for promissory estoppel can be stated in the context of a prospective at-will employee are split on the issue. Some have held that an employee can recover damages incurred as a result of resigning from the former at-will employment in reliance on a promise of other at-will employment. They have determined that when a prospective employer knows or should know that a promise of employment will induce an employee to leave his or her current job, such employer shall be hable for the reliant’s damages. Recognizing that both the prospective new employer and the prior employer could have fired the employee without cause at any time, they have concluded that the employee would have continued to work in his *24or her prior employment if it were not for the offer by the prospective employer. Although damages have not been allowed for wages lost from the prospective at-will employment, damages have been allowed based upon wages from the prior employment and other damages incurred in reliance on the job offer.

In contrast, other jurisdictions have held as a matter of law that a prospective employee cannot recover damages incurred in reliance on an unfulfilled promise of at-will employment, concluding that reliance on a promise consisting solely of at-will employment is unreasonable as a matter of law because the employee should know that the promised employment could be terminated by the employer at any time for any reason without liability. These courts have stated that an anomalous result occurs when recovery is allowed for an employee who has not begun work, when the same employee’s job could be terminated without liability 1 day after beginning work.

Promissory Estoppel Allowed

The following cases have held that a prospective employee had a cause of action for damages incurred in reliance upon a promise of employment. In Grouse v. Group Health Plan, Inc., 306 N.W.2d 114 (Minn. 1981), a pharmacist working at a drugstore desired employment with a hospital or clinic. He accepted employment with a clinic and gave 2 weeks’ notice to the drugstore. During this period, he declined a job with a hospital because he had accepted employment with the clinic. Upon reporting to work, he was told that someone else had been hired because the pharmacist did not satisfy certain hiring requirements of the clinic. He had difficulty obtaining other full-time employment and suffered wage loss as a result.

The clinic argued that the application of promissory estoppel would create an anomalous rule such that an employee who is told not to report to work the day before he is scheduled to begin has a remedy, while an employee who is discharged after the first day does not. In rejecting the clinic’s argument and allowing recovery, the court concluded that under the circumstances it would be unjust not to hold the clinic to its promise. The court stated:

*25[A]ppellant had a right to assume he would be given a good faith opportunity to perform his duties to the satisfaction of respondent once he was on the job. He was not only denied that opportunity but resigned the position he already held in reliance on the firm offer which respondent tendered him.

Id. at 116.

The court also recognized that under appropriate circumstances, promissory estoppel could apply even if the employee was fired after he had commenced employment, thus concluding that its ruling would not necessarily create an anomalous result. Since the prospective employment could have been terminated at any time, the court explained that the damages were not what the pharmacist would have earned from the clinic, but, rather, what he lost by quitting the job he held and declining at least one offer of employment elsewhere. See, also, Gorham v. Benson Optical, 539 N.W.2d 798 (Minn. App. 1995); Rognlien v. Carter, 443 N.W.2d 217 (Minn. App. 1989).

In Gorham, summary judgment was granted against the employee, who sued the employer for breach of contract, fraud, and promissory estoppel. The appellate court reversed the summary judgment on the promissory estoppel claim. The employee had been called in September 1993 about a job opportunity with Benson Optical. At the time, he earned $38,000 annually as a manager for LensCrafters. He was offered a position for $50,000 with Benson Optical, and he accepted and gave notice of resignation to LensCrafters. The employee’s last day of work for LensCrafters was October 1, and on October 3, he attended Benson Optical’s national sales meeting. On October 4, he attended a “getting to know you” meeting which left him with the impression that his employment had been or would be terminated, and on October 15, his employment was officially terminated.

Relying upon Grouse, the Gorham court found no relevant difference between the prospective Benson Optical employee, who reported for work and was terminated 1 day later, and the employee in Grouse, who was denied even 1 day on the job. Both men had relied to their detriment on the promise of a new *26job. Neither man had a good faith opportunity to perform his duties.

In Ravelo v. County of Hawaii, 66 Haw. 194, 658 P.2d 883 (1983), a police officer resigned from his position in reliance on an offer of employment in another city. His wife resigned her job, and they informed the private school where their children were enrolled that they were being removed from school. Subsequently, the police officer was told that he was not going to be hired, and he and his wife were unsuccessful in attempting to get back their previous jobs. Relying upon the Restatement of Contracts § 90 (1932), the Supreme Court reversed the trial court’s dismissal and concluded that promissory estoppel could be applied in the case of a promise of at-will employment.

In Bower v. AT & T, Technologies, Inc., 852 F.2d 361 (8th Cir. 1988), the court distinguished between an at-will employer who fires an employee 1 day after beginning work and an at-will employer who withdraws the offered employment before the employee is given an opportunity to perform. The court stated that an employer who withdraws the offered employment before the employee is given an opportunity to perform fails to keep its promise in any respect. The court concluded that the prospective employee whose offer was withdrawn had a cause of action.

In Peck v. Imedia, Inc., 293 N.J. Super. 151, 679 A.2d 745 (1996), the court stated that the application of promissory estoppel to prospective at-will employees recognizes that there may be losses incident to reliance upon a job offer itself, even though the employer can terminate the relationship at any time. The court concluded that reliance on the promise of at-will employment gave rise to a cause of action for damages flowing from the prospective employee’s giving up her prior business and moving to another state. The court stated that the prospective employer’s delay in informing the employee of its decision not to employ could give rise to damages based upon the employer’s lack of good faith and fair dealing.

In Sheppard v. Morgan Keegan & Co., 218 Cal. App. 3d 61, 266 Cal. Rptr. 784 (1990), the court held that under a theory of either breach of implied covenant of good faith and fair dealing *27or promissory estoppel, an investment banker could recover for damages incurred when a prospective employer failed to fulfill its promise of at-will employment. In reliance upon the promise of employment, the banker had resigned his previous employment and arranged to move to another city, signing a lease on an apartment there. Adopting the reasoning of Grouse v. Group Health Plan, Inc., 306 N.W.2d 114 (Minn. 1981), the court stated: “[A]n employer cannot expect a new employee to sever his former employment and move across the country only to be terminated before the ink dries on his new lease, or before he has had a chance to demonstrate his ability to satisfy the requirements of the job.” Sheppard, 218 Cal. App. 3d at 67, 266 Cal. Rptr. at 787. See, also, Comeaux v. Brown & Williamson Tobacco Co., 915 F.2d 1264 (9th Cir. 1990).

Promissory Estoppel Not Allowed

The following cases have held as a matter of law that prospective at-will employees cannot state a claim for promissory estoppel. In Bakotich v. Swanson, 91 Wash. App. 311, 957 P.2d 275 (1998), the court rejected the prospective employee’s claim for damages incurred in reliance upon a promise of at-will employment. Although the employee alleged that he terminated his prior employment in reliance on the job offer, the court held that the supposed promise was only of at-will employment and that there was no promise or reasonable expectation of permanent employment. Therefore, the court declined to extend contract principles to at-will employment absent a clear and definite promise of permanent employment which would support promissory estoppel.

In White v. Roche Biomedical Laboratories, Inc., 807 F. Supp. 1212 (D.S.C. 1992), the court held that reliance on a promise consisting solely of at-will employment was unreasonable as a matter of law, since the promise created no enforceable rights in favor of the employee other than the right to collect wages accrued for work performed. The court held that to hold otherwise would create an anomalous result insofar as the prospective employee would be placed in a better position than an employee whose at-will employment was terminated at some point after the employee began working.

*28Similarly, in Rosatone v. GTE Sprint Communications, 761 S.W.2d 670 (Mo. App. 1988), the court found that allowing claims of promissory estoppel in cases of unfulfilled promises of at-will employment would create an anomalous result to prior holdings which denied recovery to at-will employees who had commenced work. See, also, Faust v. Ryder Commercial Leasing & Serv., 954 S.W.2d 383 (Mo. App. 1997); Morsinkhoff v. DeLuxe Laundry & Dry Cleaning Co., 344 S.W.2d 639 (Mo. App. 1961).

In Heinritz v. Lawrence University, 194 Wis. 2d 606, 535 N.W.2d 81 (Wis. App. 1995), the court rejected the claim of promissory estoppel by a prospective employee who had terminated his prior employment in reliance upon an employment offer. The court stated that such reliance did not change the nature of the promise, which was for an at-will relationship that could be terminated at any time by either party without cause.

In Meerman v Murco, Inc, 205 Mich. App. 610, 517 N.W.2d 832 (1994), the court stated that to support a claim of promissory estoppel upon an unfulfilled promise of at-will employment, there must be a distinguishing feature which would remove the case from the general rule of at-will employment. The court determined that an employee who was sought out by a prospective employer and induced to leave other employment failed to establish reliance of a kind that would remove the case from the general rule regarding at-will employment. Rather, the court opined that such reliance merely involved the customary and necessary incidents of changing jobs and was not consideration to support a promissory estoppel claim. Compare, Filcek v Norris-Schmid, Inc, 156 Mich. App. 80, 401 N.W.2d 318 (1986); Hackett v Foodmaker, Inc, 69 Mich. App. 591, 245 N.W.2d 140 (1976).

Having reviewed and considered decisions from other jurisdictions, we conclude under the facts of this case that promissory estoppel can be asserted in connection with the offer of at-will employment and that the trial court erred in granting Obstetricians summary judgment. A cause of action for promissory estoppel is based upon a promise which the promisor should reasonably expect to induce action or forbearance on the part of the promisee which does in fact induce such action or *29forbearance. Here, promissory estoppel is appropriate where Goff-Hamel acted to her detriment in order to avail herself of the promised employment.

We next consider whether the trial court should have granted summary judgment in favor of Goff-Hamel. Although the denial of a motion for summary judgment is not a final order and thus is not appealable, when adverse parties have each moved for summary judgment and the trial court sustained one of the motions, die reviewing court acquires jurisdiction over both motions and may determine the controversy which is the subject of those motions. Zimmerman v. FirsTier Bank, 255 Neb. 410, 585 N.W.2d 445 (1998); Pettit v. Paxton, 255 Neb. 279, 583 N.W.2d 604 (1998).

In the present context, the questions are (1) whether Obstetricians made a definite promise of employment to GoffHamel which Obstetricians reasonably expected or should have expected would induce Goff-Hamel to terminate her present employment; (2) whether Goff-Hamel was, in fact, induced to act by such offer; (3) whether the action taken by Goff-Hamel was detrimental to her; and (4) whether justice requires that Obstetricians reimburse Goff-Hamel for damages incurred as a result of the promise of employment. See Eby v. York-Division, Borg-Warner, 455 N.E.2d 623 (Ind. App. 1983).

The facts are not disputed that Obstetricians offered GoffHamel employment. Apparently, at the direction of the spouse of one of the owners, Obstetricians refused to honor its promise of employment. It is also undisputed that Goff-Hamel relied upon Obstetricians’ promise of employment to her detriment in that she terminated her employment of 11 years. Therefore, under the facts of this case, the trial court should have granted summary judgment in favor of Goff-Hamel on the issue of liability.

However, there remains a material issue of fact regarding the amount of damages sustained by Goff-Hamel. On a motion for summary judgment, the question is not how a factual issue is to be decided, but whether any real issue of material fact exists. Kozicki v. Dragon, 255 Neb. 248, 583 N.W.2d 336 (1998); Herman Bros. v. Great West Cas. Co., 255 Neb. 88, 582 N.W.2d 328 (1998). Promissory estoppel provides for damages as jus*30tice requires and does not attempt to provide the plaintiff damages based upon the benefit of the bargain. Rosnick v. Dinsmore, 235 Neb. 738, 457 N.W.2d 793 (1990). For example, the damages sustained by an employee who quits current employment to accept another job are different than the damages sustained by an employee who had no prior employment but may have moved to a new location in reliance upon a job offer. In the latter case, wages from prior employment are not considered in the determination of damages because the party did not give up prior employment in reliance upon the new offer. In neither case are damages to be based upon the wages the employee would have earned in the prospective employment because the employment was terminable at will.

In any event, the amount of damages to be awarded, if any, is a question of fact to be determined from the circumstances of each case, i.e., as justice requires.

We therefore reverse the judgment of the trial court and remand the cause for further proceedings in accordance with this opinion.

Reversed and remanded for

FURTHER PROCEEDINGS.

Stephan, J.,

dissenting.

I respectfully dissent. In my opinion, the district court correctly determined as a matter of law that Goff-Hamel could not proceed under either a breach of contract or a promissory estoppel theory of recovery. I cannot reconcile the result reached by the majority or its rationale with our firmly established legal principles governing at-will employment. As succinctly and, in my view, correctly stated by the district court: “Since plaintiff could have been terminated after one day’s employment without the defendant incurring liability, logic dictates she could also be terminated before the employment started.”

The majority relies in part on Grouse v. Group Health Plan, Inc., 306 N.W.2d 114 (Minn. 1981), which concluded that the principles of promissory estoppel set forth in the Restatement of Contracts § 90 (1932) could apply to a termination of at-will employment which occurred before the employee actually started working because “under appropriate circumstances we *31believe [Restatement of Contracts] section 90 would apply even after employment has begun.” Grouse, 306 N.W.2d at 116. However, we held in Merrick v. Thomas, 246 Neb. 658, 522 N.W.2d 402 (1994), that an at-will employee who was discharged a short time after she began working could not, as a matter of law, assert a promissory estoppel claim for damages resulting from resignation of her previous employment. Thus, this essential premise of the holding in Grouse is directly contrary to our law. Another basis for the decision in Grouse, as quoted in the majority opinion, is that one who is offered employment has “a right to assume he would be given a good faith opportunity to perform his duties to the satisfaction” of the employer. 306 N.W.2d at 116. This concept is foreign to our law and entirely inconsistent with the established principle, acknowledged by the majority, that in the absence of contractual, statutory, or constitutional restrictions, an employer may discharge an at-will employee “whenever and for whatever cause it chooses.” Myers v. Nebraska Equal Opp. Comm., 255 Neb. 156, 163, 582 N.W.2d 362, 368 (1998). Accord Gillis v. City of Madison, 248 Neb. 873, 540 N.W.2d 114 (1995). See, also, Hamersky v. Nicholson Supply Co., 246 Neb. 156, 517 N.W.2d 382 (1994). Thus, whether an at-will employee performs in a satisfactory manner is immaterial to the employer’s right to discharge, and there is no basis under our law for an assumption that satisfactory performance by such an employee would create an entitlement to continued employment.

The majority also includes Bower v. AT & T, Technologies, Inc., 852 F.2d 361 (8th Cir. 1988), among those decisions recognizing potential liability of the employer under a theory of promissory estoppel, notwithstanding the fact that the promised employment was at will. The federal court in Bower applied the substantive law of Missouri. Three months after Bower was decided, its reasoning was repudiated by the Missouri Court of Appeals in Rosatone v. GTE Sprint Communications, 761 S.W.2d 670 (Mo. App. 1988), which found Bower to be in direct conflict with Missouri law established in Morsinkhoff v. DeLuxe Laundry & Dry Cleaning Co., 344 S.W.2d 639 (Mo. App. 1961). Referring to the holding in Bowers upon which the majority relies in this case, the court in Rosatone stated:

*32If we were to accept the holding in Bower, then we would be faced with the prospect of anomalous results such as the following: Suppose plaintiff in this case had not been told not to report to work. Instead, suppose plaintiff packed his belongings, sold his house, and moved himself and his family to a new location to commence employment with defendant. After working one day, plaintiff is discharged. The plaintiff in this example would be denied recovery altogether, although he incurred considerably more “reliance” damages than were alleged by the plaintiff in the case at bar, who, under Bower would be allowed to recover.

761 S.W.2d at 673. See, also, Faust v. Ryder Commercial Leasing & Serv., 954 S.W.2d 383 (Mo. App. 1997), holding that under Morsinkhojf and Rosatone, a promise to hire an at-will employee could not form the basis for promissory estoppel regardless of the nature of damages claimed. The logical inconsistency cited in Rosatone as the basis for rejecting Bower now exists in our jurisprudence by virtue of the holding of the majority in this case and our prior holding in Merrick v. Thomas, supra.

The conflict between the court’s decision today and the law of at-will employment is further demonstrated by the manner in which the majority addresses the issue of damages. GoffHamel’s damage claim is based entirely upon her allegation that after learning on October 3, 1993, that appellee had withdrawn its offer of employment, she was unable to find “comparable” full-time employment until May 15, 1995. The majority acknowledges that under the theory of recovery which it recognizes in this case, damages cannot be “based upon the wages the employee would have earned in the prospective employment because the employment was terminable at will.” Following the same logic, damages based upon wage loss during any interval between withdrawal of a promise of at-will employment and the securing of “comparable” employment would not be recoverable, because the promised employment could have been terminated by either party at any time after it had begun. Thus, the record reflects no factual basis upon which damages claimed by Goff-Hamel could be awarded under the remedy which the majority recognizes.

*33I would follow what I consider to be the better reasoned view, that promissory estoppel may not be utilized to remedy an unfulfilled promise of at-will employment. See, White v. Roche Biomedical Laboratories, Inc., 807 F. Supp. 1212 (D.S.C. 1992); Bakotich v. Swanson, 91 Wash. App. 311, 957 P.2d 275 (1998); Faust v. Ryder Commercial Leasing & Serv., supra; Heinritz v. Lawrence University, 194 Wis. 2d 606, 535 N.W.2d 81 (Wis. App. 1995); Meerman v Murco, Inc, 205 Mich. App. 610, 517 N.W.2d 832 (1994); Rosatone v. GTE Sprint Communications, supra; Morsinkhoff v. DeLuxe Laundry & Dry Cleaning Co., supra. I acknowledge that this reasoning would produce a seemingly harsh result from the perspective of GoffHamel under the facts of this case, but to some degree, this is inherent in the concept of at-will employment. For example, in Hamersky v. Nicholson Supply Co., 246 Neb. 156, 158, 517 N.W.2d 382, 385 (1994), a 22-year employee was discharged “ ‘without any notification, cause or reason,’ ” and although this action may seem harsh, we held that it was permissible where there was no contractual provision for employment of specific duration. Similarly, an employer which has made a significant expenditure in training an at-will employee may feel harshly treated if, upon completing the training, the employee immediately utilizes his or her newly acquired skills to secure more remunerative employment with a competitor. If the law of at-will employment were regularly bent to circumvent what some may consider a harsh result in a particular case, its path would soon become hopelessly circuitous and impossible to follow.

Employment for a specific duration imposes certain benefits and burdens upon each party to the relationship. Under our established law, parties wishing to create such a relationship must do so by contract. Where, as in this case, the parties have not chosen to impose contractual obligations upon themselves, it is my view that a court should not utilize the principle of promissory estoppel to impose the subjective expectations of either party upon the other. I agree with the view that in the context of an employment relationship, promissory estoppel “should be construed ‘in such a way that it complements, rather than undermines, traditional contract principles.’ ” White v. Roche Biomedical Laboratories, Inc., 807 F. Supp. at 1220, *34quoting Blanton Enterprises, Inc. v. Burger King Corp., 680 F. Supp. 753 (D.S.C. 1988). In my opinion, the majority has done just the opposite in this case.

For these reasons, I would affirm the judgment of the district court.

Connolly, J., joins in this dissent.

TERNUS, Justice.

Plaintiff, Ronald Dean Schoff, appeals an adverse summary judgment ruling on his claim for damages filed against his former employer, defendant, Combined Insurance Company of America. He asserts the district court erroneously held that he could not base his claim on a theory of promissory estoppel because he was an at-will employee. He also alleges error in the district court’s rejection of his theory of negligent training and supervision. We affirm.

I. Scope of Review.

Summary judgment under Iowa Rule of Civil Procedure 237(c) is appropriate only when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law. See Phipps v. IASD Health Servs. Corp., 558 N.W.2d 198, 201 (Iowa 1997). Accordingly, we examine the record before the district court to determine whether any genuine issue of material fact exists and whether the court correctly applied the law. See id. The facts are viewed “in the light most favorable to the party opposing the motion for summary judgment.” Id.

*46II. Background Facts and Proceedings.

Viewed in a light most favorable to the plaintiff, the record shows the following facts. Prior to his employment by the defendant, Schoff was a sixteen-year employee of MidAmerican Energy Corporation. On February 28, 1996, Schoff interviewed with Michael Hageman, a district manager for Combined. At the time of his interview, Schoff completed a written application for employment. The application stated that bonding by Combined’s bonding company was a condition of employment. It also asked about Schoffs criminal history. In response to the question, “Have you ever been convicted of a felony?” Schoff answered, “No.” Schoff had, however, been convicted of two serious misdemeanors, and he voluntarily disclosed this fact to Hageman during the interview. Hageman understood that Schoff revealed this information to be sure that Schoffs criminal record would not cause a problem with his potential employment by Combined.

Hageman questioned Schoff about the incident resulting in the convictions, and Schoff answered all of Hageman’s questions. Hageman never asked, however, whether Schoff had ever been charged with a felony, and Schoff did not volunteer the fact that the original charges resulting in his misdemeanor convictions were felony charges. At the time Hageman interviewed Schoff, Hageman understood that only felony convictions, as opposed to charges, were pertinent to bonding. Therefore, he believed that Schoffs criminal record, which he understood involved only misdemeanor convictions, would not adversely affect Schoffs employment with Combined. When Schoff asked Hageman whether this incident would cause any problem with Schoffs potential employment by Combined, Hageman assured Schoff that “as long as [you] have no felony convictions, [your] criminal record [will] be no problem.”

Hageman subsequently offered Schoff a position as a sales representative for Combined. Prior to accepting this offer, Schoff specifically asked Hageman whether his criminal record would have any impact on his employment with Combined. Hage-man again assured Schoff that it would not. Hageman also stated that only felony convictions were relevant to employment and bonding decisions. Schoff accepted the position offered by Hageman and terminated his employment with MidAmeri-can.

Upon acceptance of the job offered by Combined, Schoff was required to apply for fidelity bond coverage. Hageman completed an enrollment form for Schoff, in Schoffs presence, asking Schoff specific questions when the need arose. Hageman did not answer the question, “Have you ever been convicted, sentenced or imprisoned?” He told Schoff that only felony convictions were relevant and, therefore, Hageman simply wrote “N/A” after the question. Schoff signed the form and it was forwarded to the bonding company.

Schoff then entered a training period of several weeks. At the end of this period, he signed an employment contract with Combined. This agreement was on a standard form and explicitly stated that the employment contract was “terminable at will by either party.”

Schoff began selling insurance for Combined and proved to be an excellent employee. After only three months on the job, however, he was taken out of the field because his application for a fidelity bond had been denied. Schoff was told that the bonding company refused to issue a bond for him due to his criminal record. Combined asserted that the bonding company denied coverage because Schoff had been charged with two felonies and had failed to disclose the information about his conviction history on the enrollment form. Schoff was subsequently officially terminated from his employment with Combined.

*47Schoff commenced this suit against Combined, relying on two theories for the recovery of damages. First, he claimed that Combined was “estopped from terminating [him] as a result of the criminal charges which [he] had disclosed during his initial interview with [Combined’s representative], and which [the representative] had assured [him] would not adversely affect his employment [with Combined].” In an amended petition, Schoff added a negligence claim, asserting that Combined “was negligent in the training and supervision of its District Manager ... in the performance of his duties to interview and hire employees” and because of this negligence, the plaintiff suffered injury.

The district court granted Combined’s motion for summary judgment, concluding that, as a matter of law, the plaintiff was an at-will employee and could be terminated for any lawful reason. Furthermore, the court rejected the plaintiffs negligent training and supervision claim, holding as a matter of law that an employer owes no duty to a prospective employee to appropriately train and supervise its employees responsible for hiring. The plaintiff appeals.

III. Is the Theory of Promissory Es-toppel Available in an At-Will Employment Context?

A. Parties’ positions. The parties appear to agree that Schoff was an at-will employee of Combined. See generally Foote v. Simmonds Precision Prods. Co., 158 Vt. 566, 613 A.2d 1277, 1280 (1992) (holding that even where employment contract has been modified by the law of promissory estoppel, “employees for an indefinite term are still considered at-will employees, who may be discharged for any number of reasons not prohibited by the modifications”). They disagree on whether this at-will relationship could be modified by alleged oral promises made by Combined to Schoff.

The plaintiff contends that the district court erred in holding that the doctrine of promissory estoppel cannot apply in the context of an employment-at-will relationship. He maintains that this theory is just another method of establishing contract rights and, therefore, is not necessarily inconsistent with Iowa’s employment-at-will doctrine. In response, Combined argues that the promissory estoppel theory upon which the plaintiff relies should be rejected for the same reasons that our court has previously refused to allow a claim for negligent misrepresentation in the employment-at-will context.

B. Iowa’s employment-at-will doctrine. Our court has not previously considered the viability of a claim of promissory es-toppel arising out of an employment relationship. Therefore, we begin our discussion with a brief review of the status of employment at will in Iowa.

In Iowa, employment relationships are presumed to be at will. See Phipps, 558 N.W.2d at 202. The modern formulation of employment at will “permits termination at any time for any lawful reason, that is, a reason that is not contrary to public policy.” Lockhart v. Cedar Rapids Community Sch. Dist., 577 N.W.2d 845, 846 (Iowa 1998). We have recognized, however, that the employer and employee can contractually alter the at-will employment relationship. When an employer’s handbook or policy manual guarantees “that discharge will occur ‘only for cause or under certain conditions,’ ” the employer is bound by this guarantee. Anderson v. Douglas & Lomason Co., 540 N.W.2d 277, 283 (Iowa 1995) (quoting French v. Foods, Inc., 495 N.W.2d 768, 770 (Iowa 1993)). Because the plaintiff analogizes his promissory estoppel claim to the contractual alteration of the employment-at-will relationship permitted by our cases, we discuss this contract theory in more detail.

Liability of the employer based on promises made in an employee hand*48book is based on the legal theory of unilateral contract. See id. at 282 (noting that “employee handbooks that meet the requirements for a unilateral contract” are an exception to the rule that employment relationships are presumed to be at will). “A unilateral contract consists of an offer- or making a promise and an offeree rendering some performance as acceptance.” Id. at 283. Accordingly, an employee who seeks to recover under this theory must show three elements: “(1) the handbook is sufficiently definite in its terms to create an offer; (2) the handbook is communicated to and accepted by the employee so as to constitute acceptance; and (3) the employee provides consideration.” Id. With this background, we now turn to the plaintiffs claim.

B. Theory of promissory estop-pel. The theory of promissory estoppel allows individuals to be held liable for their promises despite an absence of the consideration typically found in a contract. 4 Samuel Williston, Williston on Contracts § 8.4, at 41 (1992). “[CJourts have applied the principle of estoppel in effect to form a contract, when the promisee suffered detriment in reliance on a ... promise.” Id.; see also Friedman v. BRW, Inc., 40 F.3d 293, 296 (8th Cir.1994) (stating that the effect of the doctrine of promissory estop-pel “is to imply a contract in law where none exists in fact”); Miller v. Lawlor, 245 Iowa 1144, 1152, 66 N.W.2d 267, 272 (1954) (“‘Promissory estoppel’ is now a recognized species of consideration.”); Huhtala v. Travelers Ins. Co., 401 Mich. 118, 257 N.W.2d 640, 647 n.16 (1977) (stating that in promissory estoppel claims, detrimental reliance on one side will suffice as “consideration”).

When this court adopted the doctrine of promissory estoppel, we relied on the principles of law found in the Restatement of Contracts section 90 (1932). See Miller, 245 Iowa at 1152-53, 66 N.W.2d at 272-73. Because the Restatement (Second) of Contracts contains a nearly identical statement of these principles, we quote from the latter Restatement:

A promise which the promisor should reasonably expect to induce action or forbearance of a definite and substantial character on the part of the promisee or a third person and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement of the promise.

Restatement (Second) of Contracts § 90, at 242 (1981). We have set forth the following elements as essential for recovery under a theory of promissory estoppel: “(1) a clear and definite oral agreement; (2) proof that plaintiff acted to his detriment in reliance thereon; and (3) a finding that the equities entitle the plaintiff to this relief.” Johnson v. Pattison, 185 N.W.2d 790, 795 (Iowa 1971); accord National Bank v. Moeller, 434 N.W.2d 887, 889 (Iowa 1989); In re Estate of Graham, 295 N.W.2d 414, 418 (Iowa 1980).

In the National Bank case, this court compared and contrasted our decisions in the Graham, Johnson, and Miller cases with respect to the element of “a clear and definite agreement.” National Bank, 434 N.W.2d at 889 (discussing In re Estate of Graham, 295 N.W.2d at 418-19, Johnson, 185 N.W.2d at 795-97, and Miller, 245 Iowa at 1151-56, 66 N.W.2d at 272-75). We observed that in the cases in which we found a clear and definite agreement, there was “a clear understanding by the promisor that the promisee was seeking an assurance upon which he could rely and without which he would not act.” Id. This previously unstated element is consistent with the Restatement’s express requirement that “the promisor should reasonably expect [the promise] to induce action or forbearance on the part of the promisee.” Restatement (Second) of Contracts § 90, at 242 (1981).

Given our historical reliance on the Restatement in our formulation of promissory estoppel and in the interest of unequivocally stating the elements of this theory, we conclude it is best to simply *49include the promisor’s understanding as a separate element, rather than having it subsumed in the clear-and-definite-agreement requirement. Accordingly, we state the elements of promissory estoppel as follows: (1) a clear and definite promise; (2) the promise was made with the promi-sor’s clear understanding that the promis-ee was seeking an assurance upon which the promisee could rely and without which he would not act; (3) the promisee acted to his substantial detriment in reasonable re-banee on the promise; and (4) injustice can be avoided only by enforcement of the promise.1

Having reviewed the theory of promissory estoppel, we find little to distinguish it from a unilateral contract claim with respect to its compatibility with employment at will. We certainly cannot reject a promissory estoppel claim simply because it creates an exception or obstacle to the employer’s ability to terminate an employee at will for that is precisely the effect of a unilateral contract, a theory we have embraced in the employment-at-will context. Promissory estoppel is simply another theory by which an employer may be held to his promise. The distinction in this theory is that detrimental reliance substitutes for the consideration present under a unilateral contract. We do not find anything in this difference that warrants allowing one theory in the employment-at-will context, but not the other. In conclusion, there is nothing about the employment-at-will relationship itself that precludes reliance on a theory of promissory estoppel.2

We also reject the employer’s reb-anee on our negligent misrepresentation cases as authority for the proposition that the theory of promissory estoppel is incompatible with the employment-at-will doctrine. In holding that a negligent misrepresentation claim was not viable in an *50employment-at-will situation, we held that the parties “were dealing at arm’s length” and the employment relationship “was ‘adversarial’ in nature, not advisory.” Fry v. Mount, 554 N.W.2d 263, 266 (Iowa 1996). Based on these facts, we concluded that the employer owed no duty to the employee “under this court’s interpretation of [the Restatement’s formulation of the tort of negligent misrepresentation].” Id. That interpretation limits the tort of negligent misrepresentation to defendants who are in the business or profession of supplying information, and excludes defendants in an adversarial relationship with the plaintiff. See Freeman v. Ernst & Young, 516 N.W.2d 835, 838 (Iowa 1994); Haupt v. Miller, 514 N.W.2d 905, 910 (Iowa 1994); Meier v. Mfa-Laval, Inc., 454 N.W.2d 576, 581 (Iowa 1990). Thus, the tort of negligent misrepresentation has no application in an employment relationship, where representations are made to “sell” the company rather than to guide the employee “with professional advice.” Fry, 554 N.W.2d at 267; accord Thompson v. City of Des Moines, 564 N.W.2d 839, 844 (Iowa 1997); Alderson v. Rockwell Int’l Corp., 561 N.W.2d 34, 36 (Iowa 1997).

In contrast to the theory of negligent misrepresentation, the theory of promissory estoppel has not been limited to relationships that are advisory in nature as opposed to adversarial. Therefore, the rationale for denying relief to an at-will employee under a theory of negligent misrepresentation does not apply to the doctrine of promissory estoppel.

Having determined that the employment-at-will relationship of the parties does not bar recovery under a theory of promissory estoppel, we now consider the defendant’s alternative argument. The defendant claims that, as a matter of law, the plaintiff cannot prove the elements of promissory estoppel. We begin our discussion with the requirement of a clear and definite promise.

IV. Does the Record Contain Evidence From Which a Jury Could Find a Clear and Definite Promise ?

Before we discuss the record support for this element of promissory estop-pel, we point out that the burden of proof is on the plaintiff to prove an estoppel. See National Bank, 434 N.W.2d at 889. In addition, “strict proof of all elements is required.” Id.

A. Undisputed facts. As the facts reviewed above demonstrate, it is undisputed that Schoff was fired because the bonding company refused to issue a bond. In addition, it is uncontroverted in the record that the bonding company refused to issue a bond because Schoff had two felony charges on his record and/or because he did not reveal his criminal record on his bond application. Thus, in order to estop Combined from firing him for these reasons, Schoff must establish a clear and definite promise by Combined that he would not be fired if he failed to qualify for a bond, or that he would be bonded despite his felony charges and/or failure to reveal his criminal record.

It is helpful at this juncture to compare the reasons for Schoffs discharge with the alleged promises made by Combined. Although there are some minor discrepancies between Hageman’s and Schoffs recollections of their conversations, the facts viewed most favorably to the plaintiff would support a finding that Hageman told Schoff that Schoffs criminal record would not affect his employment with Combined. In addition, the record would support a finding that Hageman told Schoff that only felony convictions were relevant to employment and bonding decisions. We turn now to whether these statements provide a basis to estop Combined from firing Schoff because he did not qualify for a fidelity bond.

B. Meaning of terms. We start our analysis with a discussion of the meaning of the requirement that the plaintiff prove a clear and definite promise. A “promise” is “[a] declaration ... to do or forbear a *51certain specific act.” Black’s Law Dictionary 1213 (6th ed.1990). A promise is “clear” when it is easily understood and is not ambiguous. See Webster’s Third New International Dictionary 419 (unab. ed.1993). A promise is “definite” when the assertion is explicit and without any doubt or tentativeness. See id. at 592.

C. Proof of a promise. Initially, we conclude that any statements made by Hageman that only felony convictions were important do not constitute an assertion that Combined would forbear a certain specific act, namely, discharging Sehoff because of his felony charges and/or his failure to be bonded. These statements by Hageman more clearly fall within the common definition of a representation: “a statement ... made to convey a particular view or impression of something with the intention of influencing opinion or action.” Id. at 1926. Statements that only felony convictions are relevant to employment and bonding decisions are not the equivalent of a declaration that Combined would not fire Sehoff because of his felony record. Hageman’s statements merely conveyed his impression or understanding of a certain fact — that only felony convictions were relevant; as a matter of law, these statements do not constitute a promise. See generally Merrifield v. Troutner, 269 N.W.2d 136, 137 (Iowa 1978) (distinguishing promissory estoppel, which requires a promise, from equitable estoppel, which is based on a misstatement of fact); 28 Am. Jur.2d Estoppel and Waiver § 48, at 658 (1966) (“In order for the doctrine of promissory estoppel to come into effect there must, of course, be a promise on which reliance may be based.... ” (Emphasis added.)).

Although this distinction may appear to be a technical one, it is of utmost importance. If we do not make a firm and clear distinction between a promise and a representation, discharged employees could simply characterize negligent misrepresentations as promises and thereby avoid our rule that employees may not recover for negligent misrepresentations made by an employer or potential employer. Consequently, we will not imply a promise from representations made by an employer, but will require strict proof that the defendant promised to do or not to do a specific act, and did not. simply state the employer’s view or impression of something.

That brings us to the other statement made by Hageman — that Schoffs criminal record would not be a problem. Although we have serious reservations whether this statement constitutes a promise, we need not resolve that issue because any such “promise” was not clear and definite, as we now discuss.

D. Proof that the promise was clear and definite. Sehoff does not claim that he and Hageman ever discussed the felony charges that were filed against Sehoff. Indeed, the record is undisputed that Sehoff never disclosed this aspect of his criminal record to Hageman. Consequently, any statement that Schoffs “criminal record” would not affect his employment is subject to some ambiguity in that the parties did not have the same knowledge with respect to the nature and extent of Schoffs criminal record. This ambiguity is crucial because Sehoff was not fired because of his criminal record in general; he was fired because he could not be bonded. Similarly, he was not denied a bond due to his criminal record in general; rather he was not bonded because he had been charged with felonies and/or had not revealed his criminal record on his bond application. As a matter of law, any “promises” that Schoffs criminal record would not be a problem simply do not clearly and definitely encompass a promise that Schoffs felony charges would not be a problem or that his failure to be bonded would not be a problem. See Neely v. American Family Mut. Ins. Co., 930 F.Supp. 360, 373-75 (N.D.Iowa 1996) (holding, as a matter of law, that assurance by insurance agent that “everything would *52be covered” was not sufficiently clear and definite to constitute a promise by insurer that coverage would be provided for executive officers, directors and employees of insured); Wing v. Anchor Media, Ltd., 59 Ohio St.3d 108, 570 N.E.2d 1095, 1098-99 (1991) (holding that promise that employee would have an opportunity to purchase an equity interest in employer was not a promise of continued employment). Therefore, the statement upon which the plaintiff bases his claim does not meet the strict standard required for a clear and definite promise.

E. Conclusion. We think the record before us fails to reveal sufficient evidence that Hageman made a clear and definite promise either that Schoffs felony charges and/or his failure to reveal them would not prevent him from being bonded, or that Schoff would not be discharged in the event he was not bonded. Consequently, Combined has shown that there is no genuine issue of material fact with respect to the first element of Schoffs promissory estoppel claim. Therefore, the district court properly granted summary judgment to Combined on Schoffs theory of promissory estoppel.3

V. Did Combined Owe Prospective Employees a Duty to Properly Train and Supervise its Employees?

Schoff also sought to recover under a negligence theory, alleging that Combined breached a duty to properly train and supervise Hageman, its district manager. A duty to conform to a standard of conduct to protect others is a necessary element in every negligence action. See Van Essen v. McCormick Enterprises Co., 599 N.W.2d 716, 718 (Iowa 1999). “Courts look to legislative enactments, prior judicial decisions, and general legal principles as a source for the existence of a duty.” Id. Because the existence of a duty is a question of law for the courts to resolve, it may appropriately be addressed by way of summary adjudication. See Fry, 554 N.W.2d at 265.

Schoff relies on the Restatement (Second) of Agency section 213 (1958) as authority for his claim. That section, dealing with a principal’s responsibility for the negligent actions of his agents, states in pertinent part:

A person conducting an activity through servants or other agents is subject to liability for harm resulting from his conduct if he is negligent or reckless:

(a) in giving improper or ambiguous orders or in failing to make proper regulations; or ....

(c) in the supervision of the activity....

Restatement (Second) of Agency § 213, at 458 (1958).

In Godar v. Edwards, 588 N.W.2d 701 (Iowa 1999), we relied on this Restatement provision in recognizing “a claim by an injured third party for negligent hiring.”4 *53588 N.W.2d at 709. We held “that an employer has a duty to exercise reasonable care in hiring individuals, who, because of their employment, may pose a threat of injury to members of the public.” Id. This duty was extended to negligent retention and negligent supervision of employees. Id.

These theories of liability only apply, however, “if all the requirements of an action of tort for negligence exists.” Restatement (Second) of Agency § 213 cmt. ⅞ at 458. Thus, the torts of negligent hiring, supervision, or training “must include as an element an underlying tort or wrongful act committed by the employee.” Haverly v. Kaytec, Inc., 738 A.2d 86, 91 (Vt.1999).

Although our appellate decisions have not addressed this component of a claim for negligent supervision, in every Iowa case where section 213 has been applied, the employee who was negligently hired or supervised wrongfully inflicted injury on the plaintiff. E.g., Godar, 588 N.W.2d at 703 (employee sexually abused student); D.R.R. v. English Enterprises, CATV, 356 N.W.2d 580, 582 (Iowa App.1984) (employee raped tenant of apartment complex). The same is true for the two cases upon which the plaintiff relies for support. See Pruitt v. Pavelin, 141 Ariz. 195, 685 P.2d 1347, 1349 (Ariz.Ct.App.1984) (employee defrauded client); Welsh Mfg. v. Pinkerton’s, 474 A.2d 436, 437 (R.I.1984) (employee stole from client). We conclude, therefore, that an employer cannot be held liable for negligent supervision or training where the conduct that proper supervision and training would have avoided is not actionable against the employee.

Here, Hageman cannot be liable for misrepresentations negligently made to Schoff because he is not in the business of supplying information. See Freeman, 516 N.W.2d at 838; Haupt, 514 N.W.2d at 910; Meier, 454 N.W.2d at 581. Nor, as we have concluded above, can there be any liability based on the theory of promissory estoppel. It follows then that Combined cannot be liable for its failure to prevent the alleged misrepresentations or promises through appropriate supervision and training of Hageman. We hold that the district court correctly granted summary judgment to the defendant on the plaintiffs negligent training and supervision claim.

AFFIRMED.