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Can an employer suddenly not pay a commission check, which has been earned?

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Can an employer suddenly not pay a commission check, which has been earned?

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The commission check is based off of percentage of sales made by the employee. January 31, 2007 the employer increased the requirements to obtain the commission however nothing was every put in writing and nothing has ever been signed by the employee. The employee did not meet the new requirements for the commision in February 2007 however the employee received a commision check. In March 2007, the employee did not meet the minimum requirements for the commision check and did not receive the commision check. The employee has received commission checks, as promised, since starting with the company with the above excluded. The employee makes above the min. wage and is considered salary exempt.

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