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State court of last resort · ST-VA-SC
Groundworks Operations, LLC v. Campbell
No. 241092Supreme Court of Virginia
241092 Groundworks Operations, LLC v. Campbell 12/30/2025 The language of the Virginia wage theft statute, Code § 40.1-29, specifically lists wages and salaries, but it does not expressly apply to commissions,…
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241092 Groundworks Operations, LLC v. Campbell 12/30/2025 The language of the Virginia wage theft statute, Code § 40.1-29, specif…
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- Supreme Court of Virginia
- First seen
- Oct 4, 2026
- Last entry
- Dec 30, 2025
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241092 Groundworks Operations, LLC v. Campbell 12/30/2025 The language of the Virginia wage theft statute, Code § 40.1-29, specifically lists wages and salaries, but it does not expressly apply to commissions, and its context does not support an interpretation that extends the statute's protections to commissions. Resting its contrary conclusion on the remedial purpose of the statute, past decisions interpreting the term "wages" in other contexts, and an interpretation by an administrative agency contained in a field manual, the Court of Appeals reversed the judgment of the circuit court concluding that Code § 40.1-29 did not apply to commissions. However, neither the plain meaning of the t…
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