In Worldcom, Inc. v. Boyle, the Fourth Circuit in a per curiam for the panel of Judges Wilkinson, Niemeyer, and Traxler, upheld the judgment for the plaintiff on its claim for restitution of the retention bonus of $900,000 paid to a former employee, who had breached his promise to stay with the company for two years.
Applying Virginia law, the Court rejected the employee defendant's various arguments that the plaintiff's claim was barred by the doctrine of unclean hands, and affirmed the dismissal of his counterclaims, which included a claim of conversion for the employer's decision to freeze his stock options after he left the company.
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