employment not terminable except pursuant to express terms] is clearly expressed and, absent evidence which shows other consideration than a promise to render services, the assumption will be that — even though they speak in terms of "permanent” employment— the parties have in mind merely the ordinary business contract for a continuing employment, terminable at the will of either party. Littell, 120 F.2d at 37. In addition to California, a number of courts have adopted that rationale in recent years. See Hartman v. C. IV. Travel, Inc., 792 F.2d 1179, 1180-81 (D.C.Cir.1986) (explaining that presumption that employment is at will applies only when there is no evidence of parties’ intent; to determine intent courts look to “such factors as the express terms of t 22, 629 (Minn.1983) (<HOLDING>); see also Eilen v. Tappin's, Inc., 16
holding that additional consideration is a factor in determining whether there is an implied contract of employment holding requirement of additional consideration and presumption of atwill employment are both rules of construction rather than substance and implied contract needs no additional consideration where intention of parties is clear holding that an additional remedy does not constitute an additional requirement holding offer of continued atwill employment did not constitute consideration for the arbitration agreement holding that offer of atwill employment is valid consideration to support an arbitration agreement