no policy requiring such a release and that Anderson relied on the STD policy provision for requiring an approved health care provider to certify that the employee’s medically certified health condition no longer impairs the employee from working. Manning asserts that reliance on such a policy is evidence of an improper motive. The record does not support this assertion. Anderson’s deposition relies on a more general company policy applying to anyone — irrespective of whether they applied for ERISA benefits — before returning to work. An unwritten work release policy does not demonstrate any impermissible motive; rather, only unwritten policies that are not consistently applied constitute evidence of an impermissible motive required for a prima facie case. See Chock, 113 F.3d at 864-65 (<HOLDING>). ARIC’s general medical certification policy,
holding that an employers sponsorship of an employees 01 visa does not establish an employment contract for a definite term holding that an employers unwritten employment policy does not demonstrate an impermissible discriminatory motive holding that evidence which suggests but does not prove a discriminatory motive is circumstantial evidence by definition holding that very little  evidence is necessary to raise a genuine issue of fact regarding an employers motive any indication of discriminatory motive  may suffice to raise a question that can only be resolved by a factfinder holding employer cannot lawfully make the signing of an employment agreement which contains an unenforceable covenant not to compete a condition of continued employment an employers termination of an employee who refuses to sign such an agreement constitutes a wrongful termination in violation of public policy