## Facts

- Community Design Corporation (CDC) employed Joseph D. Antonell as an architectural draftsman on the Brickell Key project, paid hourly with overtime.
- In fall 1980, CDC’s president promised a year-end bonus to employees still working at Christmas 1980 if the project drawings were complete by that time.
- The bonus amount was not stated as a fixed figure; the amount was to be set based on an internal recommendation process, and evidence placed it within a range.
- Antonell’s supervisor also promised Antonell a one-week paid vacation if the drawings were completed on time.
- Antonell worked overtime to meet the Christmas deadline.
- On December 24, 1980, while Antonell remained employed, the draftsmen’s drawings were collected and blueprints were made.
- Additional modifications to the drawings occurred after Christmas due to later coordination obligations and continued project development; final acceptance for construction occurred in 1982.
- CDC did not pay Antonell the bonus or provide the promised paid vacation.
- Antonell sued for breach of contract for the bonus and vacation (and also for a separate promised raise); a jury found for Antonell on the bonus and vacation claims and for CDC on the raise claim.
- The trial court entered judgment for Antonell and awarded attorney’s fees and costs; CDC appealed, and Antonell cross-appealed the amount of fees.

## Issues

1. Whether the oral promise of a bonus and one-week paid vacation was too indefinite to be enforceable given disputes about the amount, allocation, and required degree of completion.
2. Whether the evidence supported a finding that Antonell substantially performed the completion condition by Christmas 1980.
3. Whether the bonus could be treated as “wages” for fee-shifting and whether Antonell was the prevailing party despite losing on the raise claim.

## Decision

- The appellate court affirmed the judgment for Antonell on the bonus and paid-vacation claims.
- The court held the agreement was not unenforceable for indefiniteness where the existence of a contract was shown and CDC accepted the benefit of Antonell’s performance.
- The court held the evidence permitted the jury to find substantial performance of the Christmas completion condition.
- The court affirmed attorney’s fees and costs, concluding the bonus could qualify as wages for fee-shifting and Antonell was the prevailing party based on success on the main claims.
- The court affirmed the fee amount and rejected Antonell’s cross-appeal seeking a higher award.

## Legal Principles

- Courts generally avoid invalidating contracts for uncertainty when the parties’ intent to contract is shown and one party has received the benefit of the other’s performance.
- When the existence of an oral contract is established, the factfinder may determine its terms from the evidence even if some terms (such as exact price or performance detail) are disputed.
- Substantial performance may satisfy a completion condition where the parties’ conduct and project context support that the promised incentive was earned despite later revisions.
- A promised employment bonus tied to work performance may qualify as wages under fee-shifting law, supporting an employee’s recovery of attorney’s fees.
- A party may be treated as the prevailing party for attorney’s fees when it prevails on the primary claims, even if it loses on a separate claim.

## Conclusion

The appellate court upheld enforcement of an oral incentive agreement for a bonus and paid vacation, sustained the jury’s finding of substantial performance by the employee, and affirmed an attorney’s fee award on the ground that the bonus could be treated as wages and the employee prevailed on the core contract claims.


Cmty. Design Corp. v. Antonell, 459 So. 2d 343 (Fla. Dist. Ct. App. 1984)