The Sixth Appellate District reversed a judgment. The court held that discharged employees raised triable issues of fact in their action against their former employer for its breach of an alleged promise to permit senior sales agents to continue their employment under relaxed sales quotas.
Francis McCaskey, Charles Luke, and John Mellen worked for California State Automobile Association (CSAA) as insurance sales agents. They were hired between 1969 and 1976. When they were hired, McCaskey, Luke, and Mellen each signed an appointment agreement that provided that CSAA would pay commissions on new and renewal business pursuant to a compensation plan that CSAA reserved the right to modify. Those agreements also provided that either party could terminate without prior notice. The compensation plan set out formulas for calculating the commissions that McCaskey, Luke, and Mellen would be paid and included sales quotas that were called “minimum production requirements” (MPRs). Failure to meet MPRs was ground for discipline or termination.
