Day v. Summit Security Services Inc.
The plaintiff, a security guard, brought a retaliation claim under Labor Law § 215 against his former employer, Summit Security Services Inc., and alleged co-employers, New York City Health and Hospitals Corporation (HHC) and Kirk Leon. Plaintiff alleged termination resulted from a complaint about underpayment by a prior employer. HHC and Leon moved to dismiss, arguing no right of action, while Summit argued it was not the employer at the time of the protected activity. The court denied HHC and Leon's motion, concluding HHC could be considered 'any other person' under the expanded Wage Theft Prevention Act and was not exempt as a political subdivision. Summit's motion to dismiss was granted, as the court found Labor Law § 215 applied only to employers at the time of the protected activity, and the WTPA did not explicitly extend liability to subsequent employers.