Matthew L. Berman
Class actions · Employment · Civil rights
(516) 203-7180

Sales Commission Cases

Weiner v. Diebold Group, Inc.

173 A.D.2d 166, 568 N.Y.S.2d 959

Appellate Division, First Department · May 2, 1991

What the court decided

Parties "are not free to enter into contracts which violate public policy," so "if the incentive compensation payments were payments of earned wages, the plaintiff could not contract to forfeit them." New York's "long standing policy against the forfeiture of earned wages . . . applies to earned, uncollected commissions as well."

Who won

Neither side won outright. The employee's judgment was reversed and the case sent back for a new trial, because whether the pay was a discretionary bonus or earned wages, and how inconsistently the forfeiture policy had been applied, were questions for a jury.

Why it matters for salespeople

The case behind the rule that a plan cannot forfeit earned commissions no matter what it says.

Key passage: 173 A.D.2d 166 at 167-168.

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Source of the text: CourtListener (Free Law Project) — https://www.courtlistener.com/opinion/6072844/weiner-v-diebold-group-inc/. This page summarizes the decision in plain language; the court's own words are in the opinion below.