This Law Firm Publication by Foley Hoag LLP discusses two recent cases that strictly interpret the Massachusetts Wage Act in favor of former employees. In McAleer v. Prudential, the US District Court for the District of Massachusetts held that the employer owed commissions to a former employee because the amount in dispute was arithmetically determinable and earned during a period of active employment, even though the employee had left the company before the payment was made and the employer had some discretion over commissions. In Dixon v. City of Malden, the Massachusetts Supreme Judicial Court held that the City of Malden had to pay a former employee his accrued but unused vacation time at his termination. The court rejected the city's argument that continued payment of salary and benefits paid to the plaintiff after termination substituted for the unused vacation time payment.