The combined effect of Sheshunoff and Mann Frankfort may, in Armstrong’s view, tip the scales so far in the employer’s favor that it nullifies most or all of the gains made by employees in this area between the mid-1980’s and mid-1990’s. “Many employment agreements which lacked sufficient consideration because of deficient wording or actual lack of quid pro quo, will now be enforceable,” says Armstrong. “This is most definitely another pro-business decision.”