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On September 8, 2025, the Court of Appeals of Georgia issued its decision in Bible v. City of Roswell, Case Nos. A25A0947, A25A0953, 2025 WL258 7397 (Ga. App. 2025). The case involved a class action by firefighters against the City of Roswell regarding their entitlement to certain employment benefits.
In 2000, the City of Roswell switched from employing mostly full-time firefighters to employing a number of part-time firefighters. As part-time firefighters, they were not entitled to the same benefits as full-time City employees, which included retirement benefits. David Bible, the lead class plaintiff, filed suit in 2017 against the City of Roswell seeking to represent a class of similarly situated firefighters. The plaintiffs alleged that they worked at least 40 hours per week, were improperly classified as part-time, and were thereby deprived of full-time employee benefits under the City of Roswell Human Resources Policies and Procedures Manual and the City’s applicable pension and contribution plans. The plaintiffs asserted claims for breach of contract based on the Policy Manual, breach of the duty of good faith and fair dealing, quantum meruit, declaratory judgment, and attorney’s fees and expenses.
In April 2023, the trial court granted the City’s motion for summary judgment on the breach of contract claim arising from the pension plan, based on the expiration of the statute of limitations. The trial court also found that the policies and procedures manual constituted a contract, but that a factual dispute existed as to its terms and whether a breach had occurred. The court later amended its order, retracting its prior discussion on whether the policy manual was, in fact, a contract. The plaintiffs then filed a second amendment to their complaint, which the trial court dismissed upon motion by the City.
The City filed one appeal, Case No. A25A0953, seeking review of the trial court’s partial denial of its motion for summary judgment and the issue of whether the handbook constituted a contract. The plaintiffs filed a separate appeal, Case No. A25A0947, challenging the trial court’s grant of the City’s motion to dismiss the second amended complaint and its ruling on the City’s motion for summary judgment.
On appeal, the City contended that it was entitled to summary judgment on the breach of contract claims because the policy manual did not constitute a valid, enforceable contract, and that even if it did, no breach had occurred. The Court of Appeals ultimately agreed, finding that the disclaimer language in the various versions of the employee handbook precluded any theory that the policy manual was an enforceable contract. All versions of the policy manual dating back to 1983 included language stating that the manual was “intended solely to provide employees with information and guidance as to the City’s present policies and procedures” and was “not an employment agreement or employment contract.”
Why is this important?
For Georgia employers—and as a best practice in other states—handbook disclaimers can save the day. These disclaimers can prohibit breach of contract claims and even help defend against claims under 42 U.S.C. § 1981, which also require the existence of a contract. Disclaimers prevent employees from relying on language in handbooks that are meant only to provide information and guidance regarding an employer’s policies, procedures, and benefits. They are not intended to serve as the basis for contractual claims.
The City of Roswell decision is a big win for employers and serves as an important reminder to review and update employee handbooks regularly. Even a single sentence—such as a disclaimer—can often make or break a defense in employment-related litigation.
