A Massachusetts Superior Court has ruled against Shelley R. Brinkley, a former employee of Meenta, Inc., in her claims for unpaid wages and retaliation. The court's decision affects Brinkley and other employees who may seek recourse under the Massachusetts Wage Act. This ruling clarifies the definitions of wages and commissions under the law.
Brinkley filed the lawsuit against Meenta and three individuals, Gabor Bethlendy, Stephan Smith, and Torrey Ah-Tye, for unpaid wages and retaliation under the Massachusetts Wage Act, G.L. c. 149, §§ 148, 148A, 150. The case, docket number 2284CV02244-C, was filed on September 23, 2026. Brinkley sought summary judgment against Smith and Ah-Tye, while Ah-Tye filed a motion for summary judgment against Brinkley’s claims.
The dispute centers on whether the commissions Brinkley claimed were owed to her qualified as wages under the Wage Act. Brinkley argued that she was entitled to these commissions based on her employment agreement, which provided for a salary and commission structure. However, the court found that the commissions did not meet the legal definition of wages.
Brinkley was hired by Meenta in March 2021 as the Customer Success Director. She was later promoted to Vice President of Customer Success in January 2022. Her employment agreement included a commission of 1.375% of revenue, which she claimed was unpaid at the time of her termination in September 2022. Meenta acknowledged that it owed Brinkley commissions but argued that these did not qualify as wages under the Wage Act.
The court noted that the Wage Act requires that commissions must be “definitely determined” and “due and payable” to qualify as wages. The judge explained, “The record evidence that does speak to this issue...reflect that the Plaintiff's commission was to be calculated as a percentage of the overall revenue of Meenta for each quarter.” This ruling indicates that commissions based on overall company revenue do not qualify as wages under the Wage Act.
Judge Robert B. Gordon presided over the case and ruled that Brinkley’s motions for summary judgment against Smith and Ah-Tye were denied. In contrast, Ah-Tye’s motion for summary judgment was allowed, as she was not found to be an agent managing the corporation in a way that would hold her personally liable under the Wage Act.
The ruling further clarified the legal standing of individuals in corporate structures concerning wage disputes. The court stated, “To impose personal liability under the statute is evidence that the individual possessed significant management responsibilities that are at least similar to those performed by a corporate president or treasurer.” The court found no evidence that Ah-Tye had such responsibilities.
As a result of this ruling, Brinkley’s claims against both Smith and Ah-Tye were effectively dismissed. The court noted that while there was a genuine issue of material fact regarding Smith's potential liability, it was rendered moot by the conclusion that Brinkley’s claimed commissions did not constitute wages under the Wage Act.
This decision has significant implications for employees seeking to collect unpaid wages, particularly regarding how commissions are categorized. The ruling emphasizes that not all forms of compensation labeled as commissions are protected under the Wage Act, which may lead to further scrutiny of employment agreements and compensation structures in similar cases.
Moving forward, this ruling may influence how companies structure their compensation packages and how employees understand their rights under the Wage Act. Employees may need to ensure that their compensation agreements clearly define what constitutes wages versus commissions to protect their rights.
There is no indication in the court filing that Brinkley plans to appeal the decision. However, the outcome of this case could set a precedent for future wage disputes involving commissions and the responsibilities of corporate officers under the Wage Act.