Community Design Corporation v. Antonell
459 So.2d 343 (1984)
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Rule of Law:
An employer's oral promise to pay a bonus is an enforceable contract, even if some terms like the exact amount are not specified, provided the employee substantially performs the conditions required to receive it.
Facts:
- Joseph Antonell was employed by Community Design Corporation (CDC) as an architectural draftsman.
- In the fall of 1980, CDC's president, Charles Cheezum, orally promised a bonus to any employee still working at Christmas 1980 if a set of architectural drawings were completed by that time.
- The bonus amount for each employee was to be based on the recommendation of CDC's vice president, Shirley Wooster, who also separately promised Antonell a one-week paid vacation if the deadline was met.
- In reliance on these promises, Antonell worked overtime to help complete the drawings by the specified date.
- On December 24, 1980, while Antonell was still employed by CDC, the draftsmen's drawings were collected and blueprints were made.
- Following the deadline, further changes were made to the drawings, which was described as normal for the industry or required by a subsequent contract.
- CDC did not pay Antonell the promised bonus or provide the one-week paid vacation.
Procedural Posture:
- Joseph Antonell sued Community Design Corporation (CDC) in a Florida trial court for breach of contract, seeking to recover a promised bonus, a paid vacation, and a raise.
- Following a trial, a jury returned a verdict in favor of Antonell on his claims for the bonus and the paid vacation, but found for CDC on the claim for a promised raise.
- The trial court entered a final judgment against CDC and awarded attorney's fees and costs to Antonell.
- CDC, as the appellant, appealed the final judgment and the attorney's fee award to the District Court of Appeal of Florida, Third District.
- Antonell, as the appellee, filed a cross-appeal challenging the amount of the attorney's fees awarded.
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Issue:
Is an employer's oral promise to pay a bonus an enforceable contract when it is indefinite as to the specific amount and the precise degree of completion required, but the employee has performed in reliance on the promise?
Opinions:
Majority - Nesbitt, J.
Yes, an employer's oral promise to pay a bonus can be an enforceable contract even with some indefinite terms if the employee performs their side of the bargain. Courts are reluctant to deem contracts unenforceable for uncertainty, especially when one party has already performed and conferred a benefit on the other. Although the exact amount of the bonus and the specific degree of project completion were disputed, the existence of a contract was clear, and there was sufficient evidence for a jury to determine its exact terms. Once Antonell substantially performed by completing the drawings by the deadline, CDC's duty to act in good faith and pay a bonus arose. The failure to do so constituted a breach of contract, and it was proper for the jury to determine reasonable compensation.
Analysis:
This decision reinforces the legal principle that courts will endeavor to enforce contracts, even oral ones with indefinite terms, to avoid unjust outcomes where one party has already performed. It establishes that in an employment context, a promise for a bonus that induces extra work can be legally binding, shifting the burden to the employer to act in good faith. The ruling empowers juries to fill in ambiguous terms like a 'reasonable' bonus amount, making it harder for employers to use vagueness as a shield to avoid fulfilling promises that have already been relied upon by employees.
