Weiss v. DHL Express, Inc.
United States Court of Appeals for the First Circuit
718 F.3d 39 (2013)
Jeremy Weiss (plaintiff) worked for DHL Express, Incorporated (DHL) (defendant) as a district sales manager. Weiss began working for DHL in 2004 when DHL acquired Weiss’s then-employer, Airborne Express. After one year, he was promoted to regional sales director. One year later, Weiss earned the title of Regional Sales Director of the Year from DHL. DHL later promoted Weiss to director of national accounts. Shortly after naming him director of national accounts in December 2007, DHL selected Weiss to participate in DHL’s bonus plan. The employment-benefits committee reserved the sole discretion to make all determinations related to the bonus plan. Ultimately, Weiss would earn a bonus of $80,000 if he remained with DHL through the end of 2009. He received a $20,000 payment in January 2009, and $60,000 was due at the end of the year as long as Weiss did not leave DHL voluntarily or DHL did not terminate Weiss for good cause. DHL terminated Weiss in September 2009 and refused to pay him the remaining $60,000, claiming it had good cause. DHL claimed it terminated Weiss because he failed to properly manage and discipline one of his subordinates, Sergio Garcia, who caused a multi-million-dollar loss to DHL. However, Weiss was not Garcia’s direct supervisor, and no other employees who had supervisory authority over Garcia were terminated or disciplined. Weiss sued DHL for breach of contract, among other claims, alleging his termination was without good cause and that he was entitled to the bonus pay. DHL removed the case to federal court. The district court granted summary judgment in favor of DHL on all claims except for a single breach-of-contract claim. The case went to trial. The court instructed the jury to determine whether DHL terminated Weiss without good cause. The jury found for Weiss. DHL appealed.
Rule of Law
Holding and Reasoning (Howard, J.)
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