A question I get from time to time involves whether a salesperson is entitled to receive commissions due and owing following the salesperson’s termination. In Tennessee, so long as the salesperson was the procuring cause of the sale, absent an explicit or implicit agreement to the contrary, an employer is obligated to pay the salesperson post-termination commissions. A couple of cases make this point: Winkler v. Fleetline Products, Inc., 859 S.W.2d 340 (Tenn.Ct.App.1993) and Westfall v. Brentwood Service Group, Inc., 2000 WL 1721659 (Tenn. Ct. App. Nov. 17, 2000). Therefore, the practical effect of this rule is that an agreement that does not address post-termination commissions will enable the salesperson to recover unpaid commissions following termination.