Case Summary 6.1 Chambers v. Travelers Companies, 668 F.3d 559 (8th Cir. 2012)
Problem: Chambers worked for Travelers as a managing director. Questions arose regarding her management style and effectiveness, and she was fired. Among her claims against Travelers, she claimed that she was due a bonus earned. In February 2007, Travelers provided Chambers a Total Compensation Summary for the year that included a bonus of $30,000. The summary clearly stated that bonuses were at the discretion of Travelers. In September 2007, her boss provided Chambers a written performance review, giving her positive ratings in every performance category. The next month, in response to employee, a climate survey was administered to the employees whom she supervised that came back extremely negative. She was also found to have irregularities in various expense reports, and in January 2008, she was terminated. Chambers alleges that Travelers' failure to pay a $30,000 bonus for her work during 2007 breaching a unilateral employment contract that she accepted by her performance.
Case Question 1: Had Chambers performed her job well, the climate survey come back positive, and no irregularities occured in her expense reports but she was still terminated due to cutbacks, could she have compelled Travelers to pay her the bonus?
Case Question 2: Was Travelers' bonus statement in the compensation summary a unilateral offer that could be accepted by performance?