• Skip to primary navigation
  • Skip to main content

HRMorning

  • FREE RESOURCES
  • PREMIUM CONTENT
  • HR DEEP DIVES
  • PODCASTS
    • VOICES OF HR
    • WOMEN’S LEADERSHIP TODAY
  • LOGIN
  • SIGN UP FREE
  • Employment Law
  • Benefits
  • Recruiting
  • HR Technology
  • Payroll
  • Management
  • Women’s Leadership
  • More
    • Talent Management
    • Performance Management
    • Leadership & Strategy
    • Compensation
    • Policy & Procedures
    • Wellness
    • Staff Departure
    • HR Career & Self-Care
    • Health Care
    • Retirement Plans
  • Employment Law

Last Check Paid Too Late? State Court Issues Ruling

Tom D'Agostino
By: Tom D'Agostino
  • Share on

About the Author

Tom D’Agostino is an attorney and legal editor who has more than 30 years of experience writing about employment law, disability law and education law trends. He earned his B.A. degree from Ramapo College of New Jersey and his J.D. from the Duquesne University School of Law. D’Agostino, who is a member of the Pennsylvania bar, is a past member of the American Bar Association’s Section of Individual Rights and Responsibilities and the Pennsylvania Bar Association’s Legal Services to Persons with Disabilities Committee. He has provided technical assistance in the production of segments for television’s ABC World News and 20/20, and he has been quoted in periodicals including USA Today. He is also a past contributing author of Legal Rights of Persons with Disabilities: An Analysis of Federal Law, which is a comprehensive two-volume treatise addressing the legal rights of people with disabilities. Tom is passionate about baseball and authentic Italian food. When not writing, he enjoys spending time with family.

Show Less
Last Updated: April 21, 2021
2 minute engagement
When Was His Last Day

A discharged employee waited a week for his last check. He said the late last check violated state law. Was he right? 

Scott Knous began working for Massachusetts fintech company Broadridge Financial Solutions in 2018 on an at-will basis.

About a year after he started working for the company, a vice president of human resources and a managing director told him in a meeting that the company was eliminating his position.

Employer: ‘You can leave now’

At the meeting, they also told him to return his company-issued cell phone and laptop immediately. They also had him return his keycard badge and clean out his desk. And they told him to immediately stop performing his work duties and reporting to work.

That meeting happened on a Friday that preceded a regularly scheduled payday by exactly one week.

A week later, on the regularly scheduled payday, the company paid him everything he was due, including Accrued vacation pay.

Under Massachusetts law, employers must pay discharged workers all they are due on the day of discharge.

Last check was not late

Knous sued Broadridge, alleging that it broke Massachusetts law regarding payment of wages by not paying him on the day of the meeting. He said the late final paycheck violated the law.

Broadridge argued that the discharge did not occur until the payday on which Knous was paid.

A lower court ruled for Broadridge, and Knous appealed.

The U.S. Court of Appeals for the First Circuit upheld the ruling in Broadridge’s favor.

There was nothing in the relevant statute indicating that the state’s legislature intended to require employers to have discharged employees work up until the date of their official discharge, the appeals court said.

Knous was essentially trying to punish Broadridge for giving him advance notice of his last official day and then giving him paid time off through that day, the court explained. The last check was not issued too late under the state law.

Knous v. Broadridge Financial Solutions, Inc., No. 20-1617, 2021 WL 1136565 (1st Cir. 3/25/21).

Filed under
  • Employment Law
  • Share on

Get the HRMorning Newsletter

With HRMorning arriving in your inbox, you will never miss critical stories on labor laws, benefits, retention and onboarding strategies.

  • This field is for validation purposes and should be left unchanged.
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form

Free Training & Resources

Webinars

Give Your Employees Meaningful Benefits

White Papers

How Position Management Software Automates Workforce Planning

Provided by Paycom

Webinars

Improve New-Hire Engagement with Digital Onboarding

White Papers

The Retention Dilemma: Mitigating High Employee Turnover in The U.S.

Provided by PeopleGuru

SPONSORED CONTENT

HR Technology

sponsored content
The Best AI Software for HR Automation

Courtesy of G-P

Talent Management

sponsored content
Powerful Employee Retention Strategies for 2025: How to Keep Your Best People

Courtesy of PEOPLEGURU

Benefits

Health Care

Wellness

sponsored content
Proven Results: 5 Ways Teladoc Health Chronic Condition Management Transforms HR Outcomes

Courtesy of TELADOC HEALTH

Further Reading

  • Employment Law
She Admitted Poor Performance – So Why Did Court Back Her Discrimination Claim?

This employer had a perfectly good reason to let an employee go – but was still unable to squelch a claim of unlawful gender discriminati...

  • Employment Law
Mandatory retirement policy costs employer nearly $7 million

Is mandatory retirement ever allowed? Or does it always violate laws banning age discrimination? The short answer: Federal law generally...

  • Employment Law
Here’s an important FMLA rule you might not know about

The basic premise of the FMLA is pretty straightforward: Eligible employees are entitled to take job-protected leave for specified family a...

  • Employment Law
Spotlight on illegal hiring practices: Apple pays $25M for recruiting, job ad mistakes

Apple Inc. has agreed to pay $25 million to settle allegations that it engaged in illegal hiring practices, the DOJ announced in a press re...

  • Employment Law
Supreme Court Limits Nationwide Injunctions: 5 Takeaways for HR

A new Supreme Court decision has changed how federal rules can be blocked in court. While the facts of the case fall outside the employment...

  • Employment Law
Noncompete Agreement Survives Death: Here’s Why

Is it possible for a noncompete agreement to survive death? It would be a tall order for a party who dies to thereafter violate a noncom...

Get the latest from HRMorning in your inbox PLUS immediately access 10 FREE HR guides.

I WANT MY FREE GUIDES
HR Morning Logo
  • Facebook
  • Linked In
  • ABOUT HRMORNING
  • ADVERTISE WITH US
  • WRITE FOR US
  • CONTACT
  • Employment Law
  • Benefits
  • Recruiting
  • Talent Management
  • Performance Management
  • HR Technology
  • Leadership & Strategy
  • Compensation
  • Policy & Procedures
  • Wellness
  • Staff Departure
  • HR Career & Self-Care
  • Health Care
  • Retirement Plans
  • DEI

HRMorning, part of the Rover Insights Network, provides the latest HR and employment law news for HR professionals in the trenches of small-to-medium-sized businesses. Rather than simply regurgitating the day's headlines, HRMorning delivers actionable insights, helping HR execs understand what HR trends mean to their business.

Powered By Rover Insights
Privacy Policy | Terms of Service
Copyright© 2026 Rover Insights
HRMorning Logo

WELCOME BACK!

Enter your username and password below to log in

Forget Your Username or Password?

Reset Password

Lost your password? Please enter your username or email address. You will receive a link to create a new password via email.

Log In

Why do we need your credit card for a free trial?

We ask for your credit card to allow your subscription to continue should you decide to keep your membership beyond the free trial period.  This prevents any interruption of content access.

Your card will not be charged at any point during your 21 day free trial
and you may cancel at any time during your free trial.

During your free trial, you can cancel at any time with a single click on your “Account” page.  It’s that easy.