In Meson v. GATX Technology, the Fourth Circuit Court of Appeals (Richmond, Virginia) held that a plaintiff is not entitled to commissions under the "prevention doctrine" when the employer's actions merely prevent the employee from "attempting" to earn a commission, rather than prevent the employee from receiving "already earned" commissions.

In this case, the plaintiff was a regional sales manager who sold leases for information technology equipment out of her employer's Virginia office. Commission eligibility required a "commission event," which is a transaction that generated additional revenue. It also required the sales representative to be employed by the company on the date the commission became payable. The plaintiff argued that she was wrongfully denied a commission payment when her company was acquired by another and she was not hired by the purchaser, thereby preventing her from completing commission events on leases in her portfolio. The court held that the sale of the business did not "prevent" the employee from receiving commissions already earned because the employee could not show that she had any leases that were in the middle of a commission event, but merely speculated that such an event would occur.