Thank You For Submiting Feedback!
Absent an ambiguity, the court interprets a contract according to its plain terms, in a manner that gives reasonable effect to each of its provisions.
Jeremy Weiss was a rising star at DHL Express, Inc. ("DHL") until his termination in September 2009, ostensibly for his failure to properly investigate, document, and ameliorate the misconduct of an employee under his supervision. The termination occurred just months before Weiss was to receive a $60,000 bonus. Weiss filed suit in Massachusetts state court to recover the bonus on the grounds that he was terminated without good cause, which under the terms of the bonus plan entitled him to a full payout. He asserted breach of the implied covenant of good faith and fair dealing, detrimental reliance, unjust enrichment, and violation of the Massachusetts Wage Act. DHL removed the case to federal court on diversity grounds. The court allowed a single cause of action to go to the jury--a "straightforward" breach-of-contract claim. The jury found for Weiss. DHL's main claim on appeal is that the court erroneously allowed the jury to independently determine whether good cause existed for Weiss's termination because the bonus plan reserved this determination for a committee of the company. In his cross-appeal, Weiss challenges the grant of summary judgment to DHL on his Wage Act claim and the denial of his attorney's fees.
Did the court erroneously allow the jury to independently determine whether good cause existed for Weiss's termination because the bonus plan reserved this determination for a committee of the company?
The court found that the plain language of a bonus plan designated an employment benefits committee as the sole arbiter of whether a plan participant was terminated for good cause. The committee was free to deny the employee the bonus if, in its sole judgment, his employment was terminated for good cause. The committee's determination that the employee was terminated for good cause made him ineligible for the bonus, precluding his breach-of-contract claim. The employer was properly granted summary judgment on the Wage Act claim because the employee was not deprived of wages that he earned because the employer was under no obligation to pay the bonus because the bonus was contingent on either continued employment, with his performance remaining in good standing, or the committee's determination that his termination was without good cause, and neither contingency occurred.