Anthony Roberts v. Hbpo North America Inc
329325
| Mich. Ct. App. | Nov 8, 2016Background
- Plaintiff (Director of Operations) participated in a discretionary bonus program where a variable component of pay depended on meeting financial and performance targets.
- The written bonus policy required an employee to be "an active employee at the time of the bonus payout to be eligible to receive a bonus."
- The policy also stated, "HBPO will NOT pay a bonus to employees who have left the Company on their own free will."
- Plaintiff earned a 2014 bonus of $68,084 scheduled for payout on April 30, 2015; defendant terminated plaintiff on April 22, 2015 for alleged policy violations.
- Defendant moved for summary disposition under MCR 2.116(C)(8) arguing the policy unambiguously precluded employees not actively employed at payout from receiving bonuses; plaintiff argued the policy was ambiguous and should be interpreted to allow involuntarily terminated employees to receive earned bonuses.
- The trial court found the policy unambiguous and granted summary disposition for defendant; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the bonus-plan eligibility language is ambiguous | The second sentence (disallowing bonuses to employees who "left the Company on their own free will") limits the active-employment requirement to voluntary departures, so involuntarily terminated employees remain eligible | The provision plainly requires active employment at payout for all employees; the voluntary-departure sentence merely emphasizes that voluntary leavers also forfeit bonuses | The language is unambiguous: active employment at payout is required for all employees; plaintiff ineligible |
Key Cases Cited
- Maiden v. Rozwood, 461 Mich. 109 (standard for MCR 2.116(C)(8) and pleadings)
- Klapp v. United Ins. Group Agency, Inc., 468 Mich. 459 (contract ambiguity and interpretation principles)
- In re Smith Trust, 480 Mich. 19 (unambiguous contract reflects parties' intent)
- Northline Excavating, Inc. v. Livingston County, 302 Mich. App. 621 (courts cannot read words into plain contract language)