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Holland v. Earl G. Graves Publishing Co.

United States District Court for the Eastern District of Michigan
46 F.Supp. 2d 681 (1998)


Facts

Sharon Holland (plaintiff) was an employee at Earl G. Graves Publishing Co. (Graves) (defendant). At the beginning of each fiscal year, Graves provided Holland with a compensation package. The compensation package included an opportunity for Holland to earn a year-end bonus. The amount of Holland’s bonus was determined by whether Holland generated an established amount of revenue. At some point, Holland’s revenue goal was increased from the amount set in her compensation package. Graves maintained that the goal was raised midway through the fiscal year. Holland contended that the goal was raised retroactively after the fiscal year. Holland brought suit, arguing that the compensation package was an offer for a unilateral contract. As such, according to Holland, the revenue goal could not be changed once she began performing on the contract. The case was brought before federal court.

Rule of Law

Issue

Holding and Reasoning (Gadola, J.)

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