Groundworks Operations, LLC v. Campbell

**What happened:** This case involved a dispute over whether unpaid commissions count as "wages" under Virginia's wage theft law. A worker sued their employer, claiming they were owed commission payments that weren't paid. The worker tried to use Virginia's wage theft statute (Code § 40.1-29) to recover these unpaid commissions. **What the court decided:** The court ruled that Virginia's wage theft law does not cover unpaid commissions. The law specifically mentions "wages and salaries" but does not include commissions. Even though a lower appeals court had previously said commissions should be covered because the law is meant to help workers, this court disagreed. The court found that the statute's language is clear and doesn't extend to commission payments. **Why this matters for workers:** This ruling is significant for Virginia workers who earn commissions as part of their pay. If your employer refuses to pay earned commissions, you cannot use Virginia's wage theft law to recover that money. Commission-based workers like salespeople, real estate agents, and others will need to pursue unpaid commissions through different legal avenues, which may be more complicated and expensive than using the wage theft statute.