can be characterized as “new” or “future” as opposed to “continued” at-will employment. Jimenez, however, correctly responds that in Missouri, a promise of at-will employment does not qualify as consideration,- regardless of whether it is characterized as “new,” “future,” or “continued” at-will employment. Thus, it does not provide the consideration needed to support the arbitration agreement in this case. Defendants concede that Jimenez was an at-will employee. They also agree that under Morrow v. Hallmark Cards, Inc., 273 S.W.3d 15 (Mo.App.W.D.2008), a promise of “continued” at-will employment will not constitute consideration for purposes of- enforcing an arbitration agreement. See also Clemmons v. Kansas City Chiefs Football Club, Inc., 397 S.W.3d 503, 507 (Mo.App.W.D.2013) (<HOLDING>). Defendants argue, however, that this line of
holding offer of continued atwill employment did not constitute consideration for the arbitration agreement holding that a postinjury arbitration agreement was not part of a employment contract when a seamans continued employment was not conditioned upon its execution holding in an employment discrimination case that the continued employment of the plaintiffs rival in a position previously held by the plaintiff did not constitute a systemic violation holding that an alleged oral modification of a written employment agreement was not enforceable because the employees action in remaining on the job did not constitute adequate consideration holding that offer of atwill employment is valid consideration to support an arbitration agreement