Kevin Meier v. Jeff Wyler Alexandria, Inc.

CourtCourt of Appeals of Kentucky
DecidedFebruary 8, 2024
Docket2022 CA 001371
StatusUnknown

This text of Kevin Meier v. Jeff Wyler Alexandria, Inc. (Kevin Meier v. Jeff Wyler Alexandria, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin Meier v. Jeff Wyler Alexandria, Inc., (Ky. Ct. App. 2024).

Opinion

RENDERED: FEBRUARY 9, 2024; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1371-MR

KEVIN MEIER APPELLANT

APPEAL FROM BOONE CIRCUIT COURT v. HONORABLE JAMES R. SCHRAND, II, JUDGE ACTION NO. 21-CI-00710

JEFF WYLER ALEXANDRIA, INC. AND JEFF WYLER AUTOMOTIVE FAMILY, INC. APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, JONES, AND TAYLOR, JUDGES.

CALDWELL, JUDGE: Kevin Meier (Meier) appeals from a summary judgment

dismissing his claims of illegal wage deductions. We affirm.

FACTS

Meier worked as a car salesman at a Jeff Wyler1 dealership for a few

1 Meier worked at the Jeff Wyler dealership in Florence before filing suit against Appellees Jeff Wyler Alexandria, Inc. and Jeff Wyler Automotive Family, Inc. The Appellees argued to the trial court that Jeff Wyler Automotive Family, Inc. was not Meier’s employer. The trial court years. Meier was paid a set amount twice monthly as a “draw” against anticipated

commissions.

Meier could also earn additional amounts in commissions and bonuses

under a written pay plan.2 However, the additional payments for commissions and

bonuses could be reduced in certain situations – such as for imperfect customer

service surveys or an unsatisfactory mystery shopper assessment. For example, a

salesperson could earn a $100 bonus for a perfect customer service survey or a

$200 deduction for an imperfect customer survey. A salesperson could also incur

bonuses or deductions based on the percentage of potential trade-in sales which

actually occurred.

Each month, Meier and a manager signed a sheet with calculations of

the total additional payment amount due after adding up commissions and bonuses

and subtracting amounts for negative factors. Meier later stated it was unclear

from the sheets how the net total for a customer service or mystery shopper bonus

noted the argument but did not resolve any dispute on this issue. Instead, it granted summary judgment on other grounds. As the parties did not substantively argue whether either Appellee was Meier’s employer in their appellate briefs, we need not address this issue. We collectively refer to the Appellees as Jeff Wyler for brevity. 2 Relevant to the present case, Meier worked for Jeff Wyler from late 2016 until June 2020. He signed a written pay plan, which had taken effect in 2013. A new written pay plan with some additional provisions became effective in 2018. And Meier also participated in a mystery shopper assessment program which was not described in either written pay plan. Meier does not claim that he did not agree to any pay plan provisions or the terms of the mystery shopper assessment program.

-2- was calculated – such as whether a certain bonus due reflected just a bonus for a

singular event or multiple bonuses reduced by negative factors. Meier admitted

that as far as he knew, he received the payments for amounts calculated on these

sheets signed by him and a manager. But he later perceived that reductions in his

earnings for factors such as imperfect customer service surveys or failing mystery

shopper assessments violated Kentucky law.

Meier filed suit, claiming that Jeff Wyler assessed deductions which

were fines prohibited by law. Meier filed a motion for partial summary judgment,

requesting that the trial court hold that “pay deductions” for imperfect customer

service surveys, failed mystery shopper assessments, and “low conversion rates on

potential trade-in deals” were unlawful fines violating KRS3 337.060(2).

Jeff Wyler filed a response to Meier’s partial summary judgment

along with its own motion for summary judgment seeking dismissal of Meier’s

claims. Following briefing and a hearing, the trial court denied Meier’s motion for

partial summary judgment, granted summary judgment in Jeff Wyler’s favor, and

dismissed Meier’s lawsuit. Meier appealed.4

Further facts will be discussed as needed.

3 Kentucky Revised Statutes. 4 Although Meier filed the trial court action along with co-plaintiff Brandon Niehaus, Niehaus did not appeal from the trial court’s granting summary judgment in favor of Jeff Wyler.

-3- ANALYSIS

Standard of Review

An appellate court must review a trial court’s interpretation of statutes

and its grant of summary judgment de novo (without deference) on appeal. Dolt,

Thompson, Shepherd & Conway, P.S.C. v. Commonwealth ex rel. Landrum, 607

S.W.3d 683, 686-87 (Ky. 2020).

In reviewing the grant of summary judgment, we also consider

whether the trial court correctly determined that no genuine issues of material fact

exist and that the moving party was entitled to judgment as a matter of law. See id.

at 686; CR5 56.03. We also keep in mind the trial court’s obligation to view the

evidence in the light most favorable to the opposing party and to determine if

genuine issues of material fact exist – but not to decide issues of fact – when faced

with a motion for summary judgment. See Shelton v. Kentucky Easter Seals Soc.,

Inc., 413 S.W.3d 901, 905 (Ky. 2013).

Although determining if genuine issues of material fact exist is clearly

a key part of ruling on a motion for summary judgment, Meier’s appellate briefs do

not clearly identify any particular factual disputes. However, Meier states in his

reply brief: “Contrary to Jeff Wyler’s assertion, Mr. Meier does indeed dispute

Jeff Wyler’s interpretations of when and how wages are earned.”

5 Kentucky Rules of Civil Procedure.

-4- In sum, there appear to be no direct disputes about specific facts.

However, despite the lack of dispute about specific facts, the parties disagree about

whether bonuses were earned at the end of the month upon performing all

calculations or whether bonuses were earned immediately upon the occurrence of

certain events such as a perfect customer service survey. The parties also disagree

about the proper construction and application of Kentucky wage and hour statutes.

Overview of Applicable Statutes

This case hinges on application and interpretation of Kentucky wage

and hour statutes, which are set forth in KRS Chapter 337. We quote those

provisions argued by the parties regarding Meier’s illegal wage deduction claims.

KRS 337.010(1)(c)1. states:

“Wages” includes any compensation due to an employee by reason of his or her employment, including salaries, commissions, vested vacation pay, overtime pay, severance or dismissal pay, earned bonuses, and any other similar advantages agreed upon by the employer and the employee or provided to employees as an established policy.

KRS 337.060(1) states: “No employer shall withhold from any

employee any part of the wage agreed upon” except for certain enumerated

exceptions, such as authorized deductions to cover insurance premiums, which are

inapplicable here.

-5- KRS 337.060(2)(a) provides: “Notwithstanding the provisions of

subsection (1) of this section, no employer shall deduct the following from the

wages of employees: (a) Fines[.]”6

Trial Court Resolved Legal Arguments in Jeff Wyler’s Favor

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Unifund CCR Partners v. Harrell
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