Wilson v. Career Educ. Corp,, No. 12-2383 (7th Cir. 2013)Annotate this Case
Wilson worked as an admissions representative, recruiting students to enroll in CEC’s culinary arts college. CEC admissions representatives worked under a contract that gave them a bonus for each student they recruited, above a threshold, who completed a full course or a year of study. In 2010, the U.S. Department of Education issued regulations prohibiting this kind of arrangement; new rules were scheduled to take effect in July 2011. CEC decided announced to its admissions representatives that it would cease paying bonuses at the end of February 2011 and that no bonuses would be regarded as earned by that date unless the relevant student had completed the year of study or course by that time. Wilson sued, asserting that CEC owed him bonuses for “pipeline” students, whom he had recruited and who were on target to complete a full course or year of study between March and June 2011. The district court dismissed. The Seventh Circuit reversed, finding that Wilson successfully pleaded that CEC exercised its right to terminate the agreement in bad faith and in violation of the implied covenant of good faith and fair dealing.