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Ohio Case Law

CommuteAir LLC v. Bremer, 2025-Ohio-4843

Case Information

Court: Court of Appeals of Ohio Eighth Appellate District County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4843
Read the Opinion

Summary

Summary: The Court of Appeals affirmed the trial court’s judgment that the defendant breached a contract with CommuteAir by resigning before completing the required training and commitment period, obligating him to repay a pre-employment bonus and attorney fees. The court also rejected the defendant’s arguments related to constructive discharge, Railway Labor Act preemption, and newly discovered evidence.

Key Holdings

  • A signed RTP commitment letter with bonus terms is a binding written contract
  • Voluntary resignation prior to completion of required training triggers repayment obligations
  • A pre-employment training bonus is not a wage and is subject to forfeiture under contract terms
  • Constructive discharge requires intolerable working conditions not mere delays in training
  • Claims under the Railway Labor Act require a labor dispute which was not present here

More Information

CommuteAir LLC, the plaintiff-appellee, sued the defendant-appellant for breach of a contract concerning a Rotor Transition Program (RTP) bonus of $22,100. The bonus was given in exchange for a 24-month employment commitment and successful completion of flight training. The defendant voluntarily resigned from CommuteAir less than a year after his start date without completing the training, triggering the repayment obligations outlined in the contract.

The trial court found that the RTP letter was a binding written contract and that the defendant breached it by resigning early without repaying the bonus. The trial court awarded CommuteAir compensatory damages of $22,100 and $7,735 in attorney fees. The defendant argued that he was constructively discharged due to a lack of training, but the court found no evidence supporting such a claim. CommuteAir had attempted to schedule additional training, but the defendant did not respond.

On appeal, the defendant raised three arguments: that the judgment was against the manifest weight of the evidence; that the claim was preempted by the Railway Labor Act; and that a new trial should be granted based on newly discovered evidence allegedly contradicting his resignation. The appellate court rejected all three claims. It held that the evidence supported the trial court’s finding that the defendant voluntarily resigned and breached the contract.

The court also found that the Railway Labor Act did not apply because the case involved a straightforward breach-of-contract claim and not a labor dispute. Additionally, the court ruled that the defendant’s new evidence was not properly authenticated, was discoverable with due diligence, and would not likely change the outcome of the case. As a result, the trial court’s denial of a new trial was affirmed.