Fourth Circuit holds 72 hour rule not applicable to employee's post-termination commissions

Over at my firm's weblog, the BR Employment Law Blog, I posted about a recent unpublished Fourth Circuit opinion holding that the West Virginia Wage Payment and Collection Act's 72 hour rule does not apply to commissions "earned" by an employee after he is discharged. Although unpublished, the opinion provides a detailed analysis on issues that have not been directly addressed by the West Virginia Supreme Court of Appeals.