Karlen v. Jones Lang LaSalle Americas, Inc., No. 13-2379 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against JLLA for, inter alia, failure to pay him a commission on a deal that closed shortly after his departure. The district court sua sponte granted summary judgment for plaintiff and held that JLLA had wrongfully withheld commission payments. The district court awarded plaintiff the amount of the commission as well as statutory penalties for late payment under Minn. Stat. 181.03, 181.13, and attorney's fees and costs. The court concluded that the district court erred in awarding commission, wages, and statutory late payment penalties where JLLA did not owe plaintiff a commission payment at the time of termination because commission payments were subject to at least two conditions precedent that had not yet been fulfilled, and even if JLLA did eventually owe plaintiff a commission, any such amount would not have been owed until after termination, and therefore, Minn. Stat. 181.03 and 181.13 do not apply. Accordingly, the court reversed the judgment on these issues. Given the court's reversal of the underlying award, the court also vacated the later order awarding costs and attorney's fees.
Court Description: Civil case - Minnesota Payment of Wages Act. The district court erred in granting plaintiff's motion for summary judgment on commissions for a lease as the commissions were subject to at least two conditions precedent, neither of which had been met at the time plaintiff was terminated, and the commissions had not been earned and were not owing under plaintiff's employment contract; award of attorney's fees to plaintiff vacated in light of the reversal of the summary judgment.
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