Besides these legislative restrictions state and federal courts have created a wide range of judicial exemptions to employment at will. Many courts have rec¬ognized a "public policy" exemption that protects an employee's job when the dismissal would violate an important public policy. For example, some juris¬dictions protect employees from being fired for serving on a jury, for reporting a crime, or for refusing to participate in a fraudulent business practice. Some courts have also recognized an "implied contract exemption" and provide employees with protections that are implied in such employer documents as employee handbooks, job descriptions, and job advertisements. Finally, some courts have created a more general "implied covenant of good faith" exemp¬tion which is a more open-ended protection against employment practices that violate a "good faith" condition. Thus, for example, firing an employee as a means for avoiding payment of an earned annual bonus was judged an illegal violation of an implied covenant of good faith.