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

Sales Commission Cases

Yudell v. Ann Israel & Associates, Inc.

248 A.D.2d 189, 669 N.Y.S.2d 580, 1998 N.Y. Slip Op. 02109

Appellate Division, First Department · March 12, 1998

What the court decided

A commission agreement drafted by the employer is read against the employer. Where the contract paid on placements "originated by you" and said nothing about completion, it did not cut off commissions on placements completed after the recruiter left: "had defendant meant to foreclose the possibility that plaintiff might earn a post-termination commission . . . defendant could have said so explicitly."

Who won

Neither side won outright; both sides' summary judgment motions were denied, and the case went on toward trial. The employer's own files, which listed her as the recruiter on both placements, supported her claim.

Why it matters for salespeople

Useful where the company's records name you as the rep who originated or booked the deal.

Key passage: 248 A.D.2d 189 at 189-191.

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