A laid off employee sued the City of St. Louis when he was not rehired. He had been told that he would be given a call if there was an opening. Indeed, there had been four openings and he never received a call. He argued that the reason he was never called was in retaliation for his earlier complaints about fraud. The employer said he had not applied for any open position so its actions could not be considered retaliatory. The Court determined that it was not necessary for him to have actually applied for the job, since he was told that he would be called. Obviously, employers should not make promises that they do not intend to keep. Green v. City of St. Louis (8th Cir. 2007)