[authors:Ashley Mangus, Tracy Scheidtmann, and Michael Weil] On July 10, 2012, a California court of appeal held that an employer’s practice and policy of charging back advanced sales commissions following a canceled service agreement does not violate California law. The Court held that these advanced commissions are not wages; thus they do not come within the ambit of California Code of Civil Procedure section 223 which prohibits the secret payment of lower wages and exposes the employer to PAGA penalties. In Saul Deleon v. Verizon Wireless, LLC, Plaintiff brought a class action against his former employer alleging, in part, that the commission payments charged back by Verizon following a customer’s disconnection of services were actually wages not advances, and that the policies at issue were unclear and unreasonable.