Geysen v. Securitas Security Services, USA, Inc.
Connecticut Supreme Court
142 A.3d 227 (2016)
Kevin Geysen (plaintiff), an at-will salesman for Securitas (defendant) paid salary plus commissions payable only once work was performed and invoiced (with all unpaid commissions ceasing upon termination), was fired after Securitas alleged he engaged in improper business activities. Geysen claimed that allegation was pretextual, designed to avoid paying commissions he had fully earned but that simply hadn't yet been invoiced to the client; the trial court struck his implied-covenant claim while separately finding the sales-incentive plan itself violated public policy, and both sides appealed.
Whether an employer may terminate an at-will employee in bad faith solely to avoid paying commissions the employee reasonably expected to receive for services rendered under the employment contract.