Appling v. State Farm Mut. Auto. Ins. Co., 340 F.3d 769 (9th Cir. 2003)

The State Farm agents in this case alleged that the company had terminated them in breach of their independent contractor agreements. The district court granted summary judgment in favor of State Farm, and the Ninth Circuit affirmed, holding that the termination provision did not require good cause and, in fact, expressly permitted termination at will by either party. The Ninth Circuit refused to allow the agents to introduce parol evidence concerning the at-will provisions in the contract since the agents sought to vary rather than merely interpret the terms of a written contract. The Court further held that State Farm had not violated the implied covenant of good faith and fair dealing since the covenant cannot be used to impose substantive limits on the contracting parties beyond those incorporated in the specific terms of the agreement itself.