This Foley Hoag LLC memorandum discusses two Massachusetts Supreme Judicial Court decisions on the state's Payment of Wages Act (Act). The court held in Awuah v. Coverall North America, Inc. that a company may not avoid timely wage payments by classifying employees as franchisees and withholding payment until customers have paid for services. Furthermore, a company may not reclaim advances to alleged franchiees and may not require them to pay for their own workers' compensation insurance and other benefits. In Rosnov v. Molloy, the court held there is no requirement for an award of treble damages for claims arising before July 12, 2008, when the Act was amended to make treble damages mandatory.