it concerns a change of work schedule and attendant reduction in pay. Although both Shebar and Woolley involve implied contracts that protect the employee against arbitrary termination, the principle of holding an em , 46 Cal.Rptr.2d 427, 904 P.2d 834, 839 (1995) (“[TJhere is no rational reason why an employer’s policy that its employees will not be demoted except for good cause, like a policy restricting termination or providing for severance pay, cannot become an implied term of an employment contract.”); Sledge v. New Haven Coliseum Auth., 1996 WL 548163 (Conn.Super.1996) (recognizing employee’s right to establish implied contract governing right to annual performance evaluations and wage and benefit reviews); Popovich v. Bekaert Corp., 222 Ga.App. 395, 474 S.E.2d 286, 288 (1996) (<HOLDING>). The Appellate Division held that the evidence
holding that an employers promise to pay a bonus to an employee was not enforceable where the employee was already obligated under a written contract to perform the services in question holding that employee may claim contract created based on employer promise of severance pay to employee holding county employee with unenforceable contract was atwill employee holding that severance pay policy was part of employment contract holding that under texas law a contract may be terminable at will and without cause but an employer cannot promise to pay employee a certain wage and then unilaterally decide to pay employee less for work she has already performed