this was summed up to say that an employee's job could be terminated for a "good reason, a bad reason, or no reason at all". However, the employer's discretion to terminate could not violate any statutory prohibition, including termination for union membership, discriminatory termination based on a protected characteristic (e.g. race, gender, age or disability), and bringing claims for occupational health and safety, fair labor standards, retirement income, family and medical leave, and under a series of other specific Acts. Many state courts also added at least four "public policy" exceptions, to ensure that the purpose of statutes in general would not be frustrated by firing. First, employees will be wrongfully discharged if are discharged after they refused to act unlawfully, for instance for refusing to perjure themselves in court. Second, employees cannot be terminated if they insist on performing public duties such as serving on a jury or responding to a subpoena even if this affects an employer's business. Third, an employee cannot be discharged for exercising any statutory right, such as refusing to take a lie detector test or filing litigation. Fourth, employees will be wrongfully discharged if they legitimately blow the whistle on unlawful employer conduct, such as violating food labelling laws, or reporting unlawful standards in a nursing home. However none of these exceptions limit the central problem of terminations by an employer that are unrelated to an employee's conduct, capability, or business efficiency. Some states interpret the general duty of good faith in contracts to cover discharges, so that an employee cannot, for example, be terminated just before a bonus is due to be paid. However the vast majority of Americans remain unprotected against most arbitrary, irrational or malicious conduct by employers. Despite the default, and absence of job security rights in statute, a contract may require reasons before dismissal as a matter of construction. When there is a "just cause" term in a contract, courts generally interpret this to enable termination for an employee's inadequate job performance after fair warning, and job-related misconduct where the employer consistently enforces a rule, but not actions outside of the job. An employee's job may be constructively and wrongfully terminated if an employer's behavior objectively shows it no longer wishes to be bound by the contract, for instance by unfairly depriving an employee of responsibility. If a written contract does not promise "just cause" protection against termination, statements