Cook v. Coldwell Banker/Frank Laiben Realty Co.

Coldwell Banker (defendant) announced a tiered bonus program in March 1991 based on annual commissions, and Cook (plaintiff), a real estate agent, had already exceeded $30,000 in commissions — enough for the top bonus tier — by September, when Coldwell Banker announced bonuses would be paid at a March 1992 banquet and required agents to remain employed until then to receive them. Cook accepted a position with another company in January 1992 and was denied her bonus; the trial court entered judgment for her, and Coldwell Banker's motion for a directed verdict (arguing no consideration or acceptance) was denied.