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Minnesota law is silent on this issue, not making PTO guaranteed as a pay out at termination. Instead, they leave the matter to employer policy. Now, unlike some states that have payment as a default, your state does not. The employer here then could argue the reasonableness of only paying out accrued PTO, alleging that accrual only occurs as you work through the year. You can, of course, argue the other side....that without their policy stating as much, there is no reason to assume that.
The point though is that this will not be an issue handled by your state DOL. You'd have to personally sue in state court to try and allege a breach of state law through failure to pay accrued vacation. The employer will be at a disadvantage without a clearly written policy, but they do have reasonable actual arguments depending on the wording of the leave policy on what "accrual" means. Additionally, their argument will have a "common sense" aspect that courts can consider.
It's really impossible to predict the outcome. If the employer had this written into a policy it clearly would be permitted, but not having it written into a policy doesn't make it automatically illegal by your state's laws.
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