163230P.pdf   01/05/2018  Mark Boswell  v.  Panera Bread Company
   U.S. Court of Appeals Case No:  16-3230
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Arnold, Author, with Loken and Shepherd, Circuit Judges] 
   Civil case - Contracts. Defendant's bonus plan for its at-will store 
   managers was a unilateral contract; certain undertakings by the managers, 
   such as agreement to maintain confidentiality, did not convert the 
   contract to a bilateral contract; a party may not revoke an offer to make 
   a unilateral contract after the offeree has begun to perform it because 
   the offeree, at that point, has supplied consideration to make the 
   contract enforceable against the offeror to the extent it has been 
   performed; here, the managers had begun performance, and defendant could 
   not unilateraly modify the contract by imposing a cap on the bonuses; 
   argument that defendant reserved the power to modify or terminate the 
   bonus offer before the managers began performing rejected; no error in 
   rejecting defendant's novation, waiver, estoppel and commercial 
   frustration defenses. Judge Loken, concurring.