The Seventh Circuit Court of Appeals (covering mid-western states including Michigan) recently upheld a trial court's dismissal of an employee's claims, finding the commissioned sales representative, Matthew Carroll, bound by an unsigned commission plan. See Carroll v. Stryker Corporation. As an initial matter, the court recognized Carroll accepted the terms through his continued employment. The court then rejected several challenges Carroll raised to the commission plan. It found that the employer's express right to modify the contract did not eliminate the employer's promise and obligation to pay commissions on services rendered prior to any changes, so the contract contained mutual promises and was enforceable. The court further found that the disclaimer in the company's employee handbook – that the handbook was not a contract – was not relevant to evaluating the plan's enforceability.