Massachusetts Wage Act Claims for Unpaid Bonuses Dismissed

March 5, 2025

A recent Massachusetts ruling regarding unpaid bonuses is extremely important for employers in light of the wave of litigation involving the Massachusetts Wage Act. In this case, Plaintiff brought claims under the Massachusetts Wage Act for unpaid bonuses under ERISA, alleging that her former employer deprived her of guaranteed bonus payments.


This case is of particular interest as it is rare for a court to consider the substantive nature of a case during the dismissal stage. However, in this case, the judge ruled on the substantive nature of the wages Plaintiff claimed, outside of the purview of a typical motion to dismiss decision. The court decided that the compensation of a bonus under ERISA is “discretionary or contingent upon the employee remaining with the company [and] is not considered a wage subject to the wage act” and dismissed the claims of unpaid wages, only allowing the retaliation claims to proceed. The judge found that bonuses did not constitute wages as they are not earned.


This decision can help to decrease employers’ concerns about wage claims, particularly those related to bonuses and deferred compensation.



If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

Royal Attorneys Secure Summary Judgment at Massachusetts Appeals Court

December 5, 2025
Our attorneys successfully obtained summary judgment in favor of the Defendant from the Massachusetts Appeals Court in a Wage Act and contract dispute. The Complainant alleged entitlement to a substantial variable compensation award following resignation. We demonstrated that the compensation plan made such awards discretionary and contingent on continued employment at the time of payout. The Appeals Court agreed, finding that the award did not constitute wages under the Wage Act and that the Defendant acted lawfully in denying payment. All claims were dismissed in their entirety.

Amy Royal Named 2025 Super Lawyer!

By The Royal Law Firm • November 5, 2025
Attorney Amy Royal has once again been selected as a Super Lawyer ! As published by Super Lawyers Amy B. Royal is a top-rated attorney, with her firm headquartered in Springfield, Massachusetts. Providing legal representation in the New England states and New York, for a variety of different issues, Amy Royal was selected to Super Lawyers for 2014 - 2016, 2019 - 2025. Attorneys like Amy B. Royal are recognized by their peers for their outstanding work and commitment to the spirit of the legal profession. Their knowledge of the law, professional work ethic, and advocacy on behalf of their clients allow them to stand out among other attorneys in the field.