Geysen v. Securitas Security Services, USA, Inc.
Connecticut Supreme Court
142 A.3d 227 (2016)
- Written by Sean Carroll, JD
Facts
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
Issue
Holding and Reasoning (Rogers, C.J.)
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