Law School Case Brief
Carroll v. Stryker Corp. - 658 F.3d 675 (7th Cir. 2011)
In Wisconsin the quasi-contractual theories of quantum meruit and unjust enrichment are legal causes of action grounded in equitable principles and can be invoked only in the absence of an enforceable contract. Where there is an enforceable contract, the proper claim is for breach of contract; quantum meruit and unjust enrichment are unavailable.
Matthew Carroll was a commissioned sales representative assigned to solicit orders in Wisconsin for Stryker Corporation (Stryker), a medical instrument manufacturer based in Michigan. Stryker terminated Carroll's employment in 2008 because he failed to meet his quarterly sales quota. When Stryker refused to pay him the commission that Carroll felt he was rightfully owed, Carroll sued Stryker in state court for unpaid wages under Wisconsin's wage-claim statute and alternatively sought recovery under equitable contract doctrines. Stryker removed the action to federal court and later moved for summary judgment, arguing that Carroll was barred from pursuing a statutory wage claim because he worked on commission, and also that equitable contract relief was unavailable because Carroll's compensation was the subject of an express contract. Carroll responded by voluntarily dismissing his statutory claim and seeking leave to amend his complaint to add a cause of action for breach of contract. The district court entered summary judgment for Stryker, agreeing that Carroll could not recover under any equitable contract doctrine. The court also denied Carroll's motion for leave to amend because the deadline for amending the pleadings had long since passed and no reasonable cause had been shown for the undue delay. Carroll appealed.
- Can Carroll recover under equitable contract doctrine?
- Did the district court err in denying Carroll’s motion for leave to amend?
The Court held that Carroll could not recover under quantum meruit or unjust enrichment because his compensation was the subject of an express contract. His lack of signature did not defeat his acceptance of the compensation terms by performance. Anent the second issue, the Court averred that because there was no good cause for missing the deadline for amended pleadings, his motion to amend was reasonably denied.
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