Broyles v. J.P. Morgan Chase & Co.

In 2007 John Broyles (plaintiff) had an oral conversation with Foster Smith, the managing director of the international commodities group at J. P. Morgan Chase & Co. (Chase) (defendant), regarding an offer of employment. Broyles claimed that Smith’s verbal offer included bonuses or incentive pay calculated as a percentage of profits from Broyles’s trades. A few days later, Broyles received an official offer letter that he signed and returned. The offer letter explained that this written offer superseded any prior oral or written communications and was the complete agreement between the parties regarding the terms of employment. The letter also outlined Chase’s policies regarding annual incentive pay, which was at the sole discretion of the company and could be based on individual performance or the results of a department or the company as a whole. To receive incentive pay, an employee was required to be employed on the date the incentive was paid. The offer letter confirmed that Broyles’s employment was at will. On December 31, 2007, profits from Broyles’s trades surpassed $23 million dollars. However, Broyles experienced around $26 million dollars in trading losses on multiple days during the first three weeks of January 2008, including a loss of $5.2 million dollars on January 10 when he did not show up to work until after noon. Broyles was advised that he would not receive incentive pay for 2007, and he was warned that he would be terminated if he did not resign. Broyles resigned. Broyles then brought suit on a claim for breach of an oral agreement and quasi-contract, a legal remedy courts sometimes provided in the absence of a contract between parties. Chase sought summary judgment.