Hall v. United Parcel Service of America, Inc.
76 N.Y.2d 27, 555 N.E.2d 273, 556 N.Y.S.2d 21
New York Court of Appeals · May 8, 1990
What the court decided
"An employee's entitlement to a bonus is governed by the terms of the employer's bonus plan." Where the written plan said no right accrued until the employee received a participation notice, an employee who had been approved for a bonus but left two days before the notices went out had no claim to it.
Who won
The employer won on the bonus claim. (The Court held the claim was timely but rejected it on the merits; the case also rejected a negligence claim over a polygraph test.)
Why it matters for salespeople
The written plan's vesting conditions control a bonus. This is different from an earned commission under a formula, which cannot be forfeited once earned.
Key passage: 76 N.Y.2d 27 at 36-37.
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