This Ogletree, Deakins, Nash, Smoak & Stewart, P.C. memorandum discusses the recent Massachusetts Superior Court decision in Dow v. Casale. The court held that the Massachusetts Wage Act applies to the out-of-state employees of Massachusetts employers. In Dow, an employee of a Massachusetts technology company worked out of his home in Florida. The court held that the employee had sufficient contacts with the state to sue his employer under the Massachusetts Wage Act for unpaid commissions and vacation pay.