Cohan v. Medline Industries, Inc.
843 F.3d 660 (7th Cir. 2016)
U.S. Court of Appeals for the Seventh Circuit · December 9, 2016
What the court decided
Where the written plans made "negative growth" and carried-over negative balances part of how the commission was calculated in the first place, subtracting them was not a deduction from wages under section 193. The court distinguished Gennes, which involved charges against commissions already earned.
Who won
The employer won; summary judgment in its favor was affirmed.
Why it matters for salespeople
This is the decision an employer will cite. It shows why the plan's definition of "earned" matters, and why the fight is usually about when the commission was earned rather than whether a deduction was allowed.
Key passage: 843 F.3d 660 (7th Cir. 2016) at 665-668.
Read the decision (PDF) Marked with official reporter pages for citation.
Source of the text: govinfo.gov (the court's filed opinion) — https://www.govinfo.gov/app/details/USCOURTS-ca7-16-01850. This page summarizes the decision in plain language; the court's own words are in the opinion below.