As used in sections
31-71a to
31-71i, inclusive, and section
31-71l:
(1) “Employer” includes any individual, partnership, association, joint stock company, trust, corporation, the administrator or executor of the estate of a deceased person, the conservator of the estate of an incompetent, or the receiver, trustee, successor or assignee of any of the same, employing any person, including the state and any political subdivision thereof;
(2) “Employee” includes any person suffered or permitted to work by an employer;
(3) “Wages” means compensation for labor or services rendered by an employee, whether the amount is determined on a time, task, piece, commission or other basis of calculation;
(4) “Commissioner” means the Labor Commissioner.
(1967, P.A. 714, S. 1; P.A. 87-366, S. 2; June Sp. Sess. P.A. 21-2, S. 3.)
History: P.A. 87-366 amended Subdiv. (1) to include the state and its political subdivisions within “employer” definition; June Sp. Sess. P.A. 21-2 added reference to Sec. 31-71l.
Cited. 209 C. 818; 212 C. 294; 219 C. 217; 228 C. 106; 231 C. 690. Bonuses awarded solely on discretionary basis and not solely due to ascertainable efforts of the particular employee are not wages under section; managers' bonuses tied to subjective factors such as diversity and profitability, which factors are not entirely predictable or within control of specific employee, are not wages under section. 289 C. 769. Definitions in section apply to Sec. 31-72. 293 C. 515. “Wages” does not include bonus when amount of bonus is indeterminate and discretionary. 296 C. 579. A bonus, which is nondiscretionary and narrowly tailored to success of the corporate division over which plaintiff had direct supervisory authority, is a wage as defined in Subdiv. (3). 298 C. 145.
Cited. 8 CA 254; 16 CA 232; Id., 437; 18 CA 451; 27 CA 800; 37 CA 379. Under employment contract, employee's bonus could have been classified as wages for purposes of Subdiv. (3). 111 CA 287; judgment reversed in part, see 296 C. 579. Subdiv. (2): Liquor Control Commission did not abuse its discretion in finding that those who worked at cafe were “employees” because they worked at the will and interest of the cafe, had regular schedules and received compensation, and there is no legal support for claim that they are family members and cannot be considered “employees”. 120 CA 92.
Cited. 40 CS 246.
Notes of Decisions
Cited in
69
cases (
8 in the last 5 years), 1985–2026 · leading case:
Weems v. Citigroup, Inc., 961 A.2d 349 (Conn. 2008).
Weems v. Citigroup, Inc., 961 A.2d 349 (Conn. 2008).
· cites it 24× “, and its defendant subsidiaries, 2 have offered to their employees both through voluntary payroll deductions (payroll plan) and for the payment of bonuses (bonus plan), violate Connecticut’s wage statutes, General Statutes § 31-71a et seq. The plaintiffs in this class action,…”
Ass'n Resources, Inc. v. Wall, 2 A.3d 873 (Conn. 2010).
· cites it 17× “The principal issue in this appeal is whether a bonus payment, which is required to be paid under the express terms of an executive’s employment contract and calculated in accordance with a formula set forth therein, is a “wage” as defined by General Statutes § 31-71a (3). 1 The…”
Saunders v. Firtel, 978 A.2d 487 (Conn. 2009).
· cites it 16× “Specifically, the defendants contend that, because the plaintiff was an officer of Adco and was "running the company," the plaintiff was "an individual employed in a bona fide executive, administrative or professional capacity," and, therefore, he is excluded from the definition…”
Tianti v. William Raveis Real Est., Inc., 651 A.2d 1286 (Conn. 1995).
· cites it 21× “4 The trial court found that both claimants were employees for purposes of § 31-72 as that term is defined in General Statutes § 31-71a. 5 The court thereafter determined that the plaintiff was entitled to recover the sum of $24,068.”
Ziotas v. Reardon Law Firm, PC, 997 A.2d 453 (Conn. 2010).
· cites it 22× “The issue raised by this appeal is whether a year-end bonus, the amount of which is discretionary, constitutes wages under General Statutes § 31-71a (3). 1 The plaintiff, Angelo A.”
Shortt v. New Milford Police Dep't, 562 A.2d 7 (Conn. 1989).
· cites it 15× “This appeal involves two questions of construction concerning the scope of General Statutes § 31-72 1 : (1) whether a municipality constituted an *296 “employer” for the purposes of this statute under the definition contained in General Statutes § 31-71a (1) prior to its…”
Ziotas v. Reardon Law Firm, P.C., 959 A.2d 1013 (Conn. App. Ct. 2008).
· cites it 12× “Specifically, he argues that the court improperly concluded that the bonus portion of his compensation, as alleged in his complaint, did not fall within the definition of wages, as that term is used in General Statutes § 31-71a (3). The defendant argues that the plaintiff waived…”
Datto Inc. v. Braband, 856 F. Supp. 2d 354 (D. Conn. 2012).
· cites it 10× “” Conn. Gen.Stat. § 31-71a(3). Conn. Gen.Stat.”
Butler ex rel. Skidmore v. Hartford Technical Inst., Inc., 704 A.2d 222 (Conn. 1997).
· cites it 6× “Specifically, *458 the defendant claims that: (1) § 31-72 does not impose liability on officers or agents of a corporate employer; and (2) he can not be an “employer” as the term is defined in General Statutes § 31-71a (1) because the employer in this case was a corporation and…”
Roberts v. Triplanet Partners, LLC, 950 F. Supp. 2d 418 (D. Conn. 2013).
· cites it 7× “The plaintiff, Benjamin Roberts (“Roberts” or “the plaintiff’), brought this action against his former employer, Triplanet Partners LLC (“TriPlanet”), and TriPlanet’s managing members, Sophien Bennaceur (“Sophien”) and Imed Bennaceur (“Imed”) (collectively, “the defendants”),…”
Christensen v. Bic Corp., 558 A.2d 273 (Conn. App. Ct. 1989).
· cites it 6× “The plaintiff filed a cross appeal asserting error in the trial court’s refusing to permit the jury to find that a bonus constituted a wage within the meaning of General Statutes § 31-71a. We find error on the appeal.”
Mytych v. May Dep't Stores Co., 793 A.2d 1068 (Conn. 2002).
· cites it 4× “” Although the statute lists certain nonexclusive factors that may assist in the computation of an employee’s wage, it fails to set forth a specific formula by which wages must be calculated or determined.”
— Conn. Gen. Stat. § 31-71a(1) — 1 case
— Conn. Gen. Stat. § 31-71a(2) — 2 cases
Saunders v. Firtel, 978 A.2d 487 (Conn. 2009).
“Specifically, the defendants contend that, because the plaintiff was an officer of Adco and was "running the company," the plaintiff was "an individual employed in a bona fide executive, administrative or professional capacity," and, therefore, he is excluded from the definition…”
— Conn. Gen. Stat. § 31-71a(3) — 11 cases
Datto Inc. v. Braband, 856 F. Supp. 2d 354 (D. Conn. 2012).
“” Conn. Gen.Stat. § 31-71a(3). Conn. Gen.Stat.”
Roberts v. Triplanet Partners, LLC, 950 F. Supp. 2d 418 (D. Conn. 2013).
“The plaintiff, Benjamin Roberts (“Roberts” or “the plaintiff’), brought this action against his former employer, Triplanet Partners LLC (“TriPlanet”), and TriPlanet’s managing members, Sophien Bennaceur (“Sophien”) and Imed Bennaceur (“Imed”) (collectively, “the defendants”),…”
Weems v. Citigroup, Inc., 961 A.2d 349 (Conn. 2008).
“, and its defendant subsidiaries, 2 have offered to their employees both through voluntary payroll deductions (payroll plan) and for the payment of bonuses (bonus plan), violate Connecticut’s wage statutes, General Statutes § 31-71a et seq. The plaintiffs in this class action,…”
— Conn. Gen. Stat. § 31-71a(l) — 1 case
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