Sciborski v. Pacific Bell Directory, a recent California Court of Appeal decision, emphasizes the importance of clear language in commission plans and agreements.  Pacific Bell clawed back a commission payment to plaintiff Sciborski on the grounds that she had not earned the commission – i.e., the prior payment was merely an advance – because she was improperly assigned to an account for which she was not eligible.  Sciborski argued that Pacific Bell's admitted clerical error was an improper basis to claw back the commission, because the at-issue bargaining agreement did not include proper account assignment as a prerequisite for earning commissions.  The court agreed with Sciborski:  "Absent an express provision to this effect, Pacific Bell was not entitled to unilaterally declare that the commission was not earned and use self-help measures to deduct funds from Sciborski's wages that had already been paid to her."