Kevin Geysen v. Securitas Security Services USA, Inc.

Summary

The court held that an at-will employment agreement making commission eligibility contingent on client invoicing before termination was enforceable and did not violate the wage statutes or public policy. The plaintiff nevertheless stated a contract claim for breach of the implied covenant of good faith and fair dealing by alleging that the employer terminated him in bad faith to avoid paying commissions. His separate wrongful-discharge claim was properly stricken because the commissions were not earned under the agreement and the wage statutes did not establish a broader public policy protecting unearned wages.