The Alberta Court of Appeal recently overturned a decision from the Alberta Court of Queen’s Bench that found that an employer owed an employee a common law duty of “reasonable exercise of discretionary contractual power” and that the employee was entitled to receive a bonus after termination, even though the language at issue stated that the employee had to be “actively employed” to receive the bonus. The Court of Appeal rejected both findings of the trial court and concluded that there was no such duty of reasonable exercise of discretionary contractual power and that the employee was not entitled to the bonus because he did not satisfy the requirement of “active employment”.