4

Titchener v. Avery Coonley School, 350 N.E.2d 502, 508 (Ill. 1976). Accord Tollefson v. Roman Catholic Bishop of San Diego, 268 Cal. Rptr. 550 (Cal. App. 1990) (“although termination contrary to the express terms of an employment contract may [be the basis of a lawsuit], a decision not to enter into a new contract or renew an expired one is not”).