Kaufmann v. SIEMENS MEDICAL SOLUTIONS USA, INC.
638 F.3d 840
8th Cir.2011Background
- Kaufmann has worked for Siemens since 2000 in sales roles; fiscal year 2004 he served as national sales director for Millennium Territory.
- Kaufmann supervised Millennium's exclusive ultrasound equipment sales force, not Siemens's direct sales force.
- Siemens' direct sales force operated in Millennium's territory, effectively poaching sales from Millennium.
- Pay Plan governed commissions: paid monthly, credited only to the territory where the sale occurred, and only if personally responsible for that sale.
- Kaufmann sought additional compensation for direct-force sales in Millennium's territory; Patton allegedly agreed, but Siemens reversed and did not pay.
- Kaufmann filed suit in 2006 in state court; Siemens removed to federal court and won summary judgment on the 2003 wage claim and 2004 incentives; a jury awarded Kaufmann for 2004 wages and found intentional withholding, later reversed for liquidated damages, and the district court denied JMOL on the wage claim under 2003.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 2003 wage claim is time-barred | Kaufmann seeks tolling via equitable estoppel. | Siemens argues no true misrepresentation and no tolling. | Equitable estoppel fails; summary judgment for Siemens affirmed on 2003 wages. |
| Whether Kaufmann is entitled to liquidated damages for 2004 wages | Wages and intentional withholding trigger 91A.8 liquidated damages. | Pay Plan bonuses are discretionary, not wages due under 91A.3. | Liquidated damages not available; 2004 claim treated as discretionary bonus. |
| Whether Kaufmann's pay for 2004 was wages or a discretionary bonus under the IWPCL | Compensation for poached sales constitutes wages under 91A.2(7). | Compensation was not due as wages, as Kaufmann had no direct responsibility for those sales. | Pay Plan did not entitle Kaufmann to those commissions; the payment resembled a discretionary bonus. |
Key Cases Cited
- Dallenbach v. MAPCO Gas Prods., Inc., 459 N.W.2d 483 (Iowa 1990) (bonuses not wages due; liquidated damages not available for such bonuses under 91A.8)
- Runyon v. Kubota Tractor Corp., 653 N.W.2d 582 (Iowa 2002) (liquidated damages reserved for regular wages and commissions, not discretionary bonuses)
- Boehme v. Fareway Stores, Inc., 762 N.W.2d 142 (Iowa 2009) (equitable estoppel requires misrepresentation with intent to mislead; burden on plaintiff)
- Hook v. Lippolt, 755 N.W.2d 514 (Iowa 2008) (estoppel elements include false representation and reliance)
- State v. Heard, 636 N.W.2d 227 (Iowa 2001) (interpretation of statutory questions in context of this case)