THE AMERICAN INSTITUE FOR CHARTERED PROPERTY CASUALTY UNDERWRITERS v. POSNER

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 22, 2022
Docket2:19-cv-05369
StatusUnknown

This text of THE AMERICAN INSTITUE FOR CHARTERED PROPERTY CASUALTY UNDERWRITERS v. POSNER (THE AMERICAN INSTITUE FOR CHARTERED PROPERTY CASUALTY UNDERWRITERS v. POSNER) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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THE AMERICAN INSTITUE FOR CHARTERED PROPERTY CASUALTY UNDERWRITERS v. POSNER, (E.D. Pa. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

THE AMERICAN INSTITUTE FOR : CIVIL ACTION CHARTERED PROPERTY : CASUALTY UNDERWRITERS, : NO. 19-5369 et al. : Plaintiffs : : v. : : SYDNEY POSNER, et al. : Defendants :

NITZA I. QUIÑONES ALEJANDRO, J. JUNE 22, 2022

MEMORANDUM OPINION

INTRODUCTION

Defendant/Counterclaim Plaintiff Sydney Posner (“Posner”) asserted counterclaims against her former employer, Defendants The American Institute for Chartered Property Casualty Underwriters and The Institutes LLC (collectively, “AICPCU”), for breach of contract and unpaid wages under the Pennsylvania Wage Payment and Collection Law (the “WPCL”), 43 Pa. Cons. Stat. § 260.1 et seq., premised on her allegations that AICPCU failed to pay her severance and earned commissions following her termination of employment on September 20, 2019. Before this Court are AICPCU’s motion for summary judgment with respect to Posner’s counterclaims, [ECF 124], Posner’s response in opposition, [ECF 130], and AICPCU’s reply, [ECF 135]. The issues raised by the parties have been fully briefed and are ripe for disposition. For the reasons set forth herein, AICPCU’s motion for summary judgment is granted in part and denied in part. BACKGROUND When ruling on a motion for summary judgment, a court must consider all record evidence and supported relevant facts in the light most favorable to the non-movant—here, Posner. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986); Galena v. Leone, 638 F.3d 186, 196 (3d Cir. 2011). The facts relevant to the underlying motion are summarized as follows:1

AICPCU acquired the assets of Posner’s previous employer, CLM Group, Inc. AICPCU offered to retain Posner in her same position (Chief Relationship Officer), submitting a written offer of employment on May 28, 2018 (the “Initial Offer Letter”). In addition to the offered salary, retention bonus, and various benefits, the Initial Offer Letter included the following with respect to commissions:

You will earn 8% commission on all sales. Commissions will be paid out three times per year, after the following periods or events: commissions earned from sales during the period of January through June, commissions earned from sales during the period of July through December, and commissions earned from sales for the CLM Annual Conference.

You must be an active employee of The Institutes on the date of the commission payout to receive the commission pay.

***

Any adjustments to your compensation and commission structure will be at the sole discretion of The Institutes in accordance with its business needs and expectations.

This Initial Offer Letter also included the following:

As a condition of your employment with The Institutes, you will be required to sign and return the enclosed Confidentiality, Non- Solicitation and Noncompetition Agreement.

To accept this offer, kindly sign and date where indicated below no later than June 4, 2018 and return the signed letter, and the signed

1 These facts are taken from the parties’ briefs, exhibits, and statements of facts. To the extent that any facts are disputed, such disputes will be noted and, if material, will be construed in Posner’s favor pursuant to Federal Rule of Civil Procedure (“Rule”) 56. Confidentiality, Non-Solicitation and Noncompetition Agreement, to Human Resources.

Included with the Initial Offer Letter was the referenced Confidentiality, Non-Solicitation and Noncompetition Agreement (the “Original Proposed Agreement”). The Original Proposed Agreement included a non-solicitation provision and a non-competition provision. The bottom of each page of the four- page Original Proposed Agreement included a place for both Posner and AICPCU to insert their initials. In addition, the fourth page included a place for Posner to sign the agreement. Notably, the Original Proposed Agreement contained no provision for severance.

Upon receipt, Posner forwarded the Initial Offer Letter and Original Proposed Agreement to her attorney, Richard E. King (“Attorney King”), for review on June 1, 2018. The next day, on June 2, Attorney King forwarded a redlined, edited version of the Original Proposed Agreement to Posner (the “King Redline”). Attorney King described his edits as “pretty hard core, but a good place to start.” Attorney King’s edits included deletion of the entire “Non-Competition” provision and most of the related “Restricted Period And Territory” provision. At the end of these deletions, Attorney King inserted the following comment in the margin of the document:

Commented [REK2]: If a non-compete is a deal breaker, then if enforced, Sydney must have severance of 2 years of salary and average bonus of last 2 years (including time prior to The Institutes purchase. This severance would apply to any enforcement of the Non-Competition and/or Restricted Period and Territory, including but not limited to termination For Cause.

Notably, other than the above reference to severance appearing in the margin comment, Attorney King did not add any severance provision to the body of the agreement. Later in the King Redline, Attorney King inserted another comment in the margin of the document addressing the choice of law provision:

Syd, if they push for the non-compete and you have to give in, I would try to argue for Florida law to apply. I did some quick research and Florida’s non-compete laws are just a little better than Penn, plus you will get home field advantage.

On June 4, 2018, Posner emailed Katherine Horowitz (“Horowitz”), a senior vice president with AICPCU, with questions about the paperwork. Posner wrote the following:

• On the first page it lists my annual salary and retention bonus (thank you), but it does not list my 8% commission. • I am finalizing all of the documents and came across the Confidentiality, Non-Solicitation and Noncompetition agreement. I have forwarded it to my attorney for review but will need to discuss this as I currently do not have a Non- Compete with CLM. Is there a good time/day for you?

Posner and Horowitz spoke on the phone on June 6. During this conversation, Posner expressed hesitancy to agree to a non-competition provision without the addition of a severance provision. Posner voiced no issue with the non-solicitation provision.

At 9:19 AM on June 6, after the telephone conference, Horowitz sent Posner an “updated offer letter” that included, inter alia, a description of Posner’s salary, bonus, and commission structure. This “updated offer letter,” dated May 30, 2018, contained the same terms described above and repeatedly referenced, but did not include a copy of, the Confidentiality, Non-Solicitation and Noncompetition Agreement.2

Later that day (June 6), at 3:24 PM, Posner sent Horowitz an email that contained a signed copy of the Initial Offer Letter and a redlined, edited version of the Original Proposed Agreement (the “Posner Redline”), which Posner described as the “Non-compete with edits from my attorney that are suggestions and a starting point and by no means demands.” The Posner Redline, like the King Redline described above, deleted the entire “Non-Competition” provision and most of the related “Restricted Period And Territory” provision. At the end of these deletions was the following comment in the margin of the document (the “Margin Severance Comment”):

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THE AMERICAN INSTITUE FOR CHARTERED PROPERTY CASUALTY UNDERWRITERS v. POSNER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-american-institue-for-chartered-property-casualty-underwriters-v-paed-2022.