Runyon v. Kubota Tractor Corp.

Jake Runyon (plaintiff) was a regional sales manager for Kubota Tractor Corporation (Kubota) (defendant), a California corporation. When Runyon was hired in 1977, he lived in Iowa. A few years later, Runyon moved to Missouri but retained responsibility for several Kubota dealerships in Iowa. Runyon visited the Iowa dealerships regularly, maintained telephone contact with the Iowa dealers, and attended trade shows in Iowa. Runyon’s compensation included salary, commissions, and a discretionary bonus. Approximately 70 percent of Runyon’s commissions were attributable to sales in Missouri, with the remainder resulting from sales to dealers in Nebraska and Iowa. Runyon filed his income tax returns in Missouri. In accordance with the terms of Kubota’s discretionary-bonus program, Kubota deducted $3,979 from Runyon’s 1999 bonus for the cost of inventory that Runyon’s dealerships in Missouri and Iowa sold but did not pay Kubota for. The deduction amounted to a 15 percent reduction in the bonus that Runyon otherwise would have received. Runyon sued Kubota, arguing that the deduction violated the Iowa Wage Payment Collection Law (wage statute) and that Kubota should pay liquidated damages under the wage statute for intentionally failing to pay wages that Runyon was owed. The trial court found, as a matter of law, that the wage statute applied to the dispute but that Runyon was not entitled to liquidated damages. The jury returned a verdict for Runyon on the wage claim. Kubota appealed, and Runyon cross-appealed on the question of the availability of liquidated damages.