Geysen v. Securitas Security Services, USA, Inc.
Connecticut Supreme Court
142 A.3d 227 (2016)
Kevin Geysen (plaintiff) was an at-will employee for Securitas Security Services, USA, Inc. (defendant), a security company. Geysen’s job was to procure business for the company. Geysen was paid a salary, and also a commission for contracts that he procured. Securitas’s sales-incentive plan provided that commissions would be paid only after work was performed and invoiced to the client. The plan provided further that upon an employee’s termination, “all commissions cease,” except for those invoiced prior to termination. Securitas terminated Geysen’s employment, alleging that he had engaged in improper business activities. Geysen sued Securitas on a number of grounds, including breach of the implied covenant of good faith and fair dealing. Specifically, Geysen claimed that Securitas’s allegation that he had engaged in improper business practices was merely a pretext to avoid paying outstanding commissions that had been fully earned but simply not yet invoiced to the client. The trial court granted Securitas’s motion to strike this claim. However, the trial court also held that the sales-incentive provision violated public policy because it prevented commissions from being paid when an employee’s services were performed in full. Both parties appealed.
Rule of Law
Holding and Reasoning (Rogers, C.J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.