Wilson v. Career Education Corp.

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in action alleging that defendant breached implied covenant of good faith and fair dealing by terminating its bonus plan prior to time when said plan was required to cease due to new governmental regulation that prohibited defendant from giving said bonuses to plaintiff and his co-workers based on their ability to recruit and retain students to defendant’s school. Terms of bonus plan allowed defendant to change terms of plan at any time. Moreover, while governmental regulation was not scheduled to take place for another five months after defendant discontinued bonus plan, plaintiff could not reasonably expect that bonuses would not be terminated prior to effective date of regulation, and actual motivation for termination of bonus plan, i.e., financial downturn in business, cannot be characterized as being in bad faith or beyond objectively reasonable expectations. Fact that defendant gave different rationale for discontinuing bonus plan did not require different result.