Andrew Mirchel v. RMJ Securities

In Andrew Mirchel v. RMJ Securities, 205 AD2d 388 (1st Dept. 1994) an at-will employee sued to collect an earned bonus. The Appellate Division reversed the lower court's decision granting the employer summary judgment. The Court stated: "Whether unpaid incentive compensation under a defendant's bonus plan constitutes a discretionary bonus or earned wages not subject to forfeiture is an issue of fact. Employees in this State may enforce an agreement to pay an annual bonus made at the onset of the employment relationship where such bonus constitutes an integral part of plaintiff's compensation package" (Id. at. 389.)