Holland v. Earl G. Graves Publishing Co.

Each fiscal year, Graves (defendant) gave employee Sharon Holland (plaintiff) a compensation package offering a year-end bonus tied to hitting a set revenue goal. At some point Holland's revenue goal was increased, though the parties disputed whether that happened mid-year or was applied retroactively after the fiscal year ended; Holland never agreed to the change. Holland sued, arguing the original compensation package was an offer for a unilateral contract that, once she began performing, could no longer be unilaterally altered.