In Ryan v. Kellogg Partners Inst. Servs. (19 NY3d 1, 968 N.E.2d 947, 945 N.Y.S.2d 593 [2012]), the plaintiff "testified that he left his well-paying job at another securities firm to join Kellogg in reliance upon the managing partner's promise that his compensation package for 2003 would consist of a base salary of $175,000 and a guaranteed, non-discretionary bonus of $175,000 to be paid to him in late 2003 or early 2004" (id., at 9).

The jury found that the plaintiff's job offer included a guarantee to pay a non-discretionary bonus of $175,000 to attract him from his then employer, and that the new employer asked for and received the plaintiff's consent to delay this bonus payment for a year.

After the plaintiff was fired, he sued to recover the $175,000 deferred payment.

The Court of Appeals held that the plaintiff's "bonus was expressly linked to his labor or services personally rendered, . . . the bonus had been earned and was vested before he left his job at Kellogg, and its payment was guaranteed and non-discretionary as a term and condition of his employment" (id. at 11)