Last week, the Cuyahoga County Court of Appeals affirmed the terms of an employer’s hiring bonus when the employee resigned less than a year after starting training and was required to repay the entire amount of the five figure hiring bonus. CommuteAir, L.L.C. v. Bremer, 2025-Ohio-4843. The Court rejected the defendant’s argument that he was constructively discharged because there was no evidence that his working conditions were intolerable. He claimed that he could not complete training because of his wife’s illness and a death in the family, but could not refute the employer’s evidence that it attempted to reschedule his training without his cooperation in communication. Finally, it rejected his argument that the hiring bonus was a non-forfeitable wage instead of a bonus that could be subject to conditions or that this breach of contract claim was preempted by the Railway Labor Act.
According to the Court’s opinion, the employer hired the
defendant for its pilot training program.
He signed an agreement for a hiring bonus of $22K that he had to repay
in full if he failed to complete his training or voluntarily resigned or was
fired for cause in less than a year and half of the bonus if after one year,
but less than two. He delayed the
commencement of his training by more than six months and then resigned less
than a year later. The agreement required
him to repay the full amount, plus fees and costs.
NOTICE: This summary is designed merely to inform and alert
you of recent legal developments. It does not constitute legal advice and does
not apply to any particular situation because different facts could lead to
different results. Information here can change or be amended without notice.
Readers should not act upon this information without legal advice. If you have
any questions about anything you have read, you should consult with or retain
an employment attorney.
