In Weiss v. DHL Express, Inc., the First Circuit held that the employee was not entitled to a bonus based on the language of the company’s bonus plan and the bonus plan committee’s determination that the employee had been terminated for good cause. The Court also held that the employee had no recourse under the Massachusetts Wage Act because his bonus did not qualify as wages under the Act. Nos. 12-1853 and 12-1864 (1st Cir. June 3, 2013).