Capers v. Giuliani
Plaintiffs, public-assistance recipients in New York City's Work Experience Program (WEP), alleged unsafe working conditions in their sanitation-related assignments, claiming violations of OSHA standards and inadequate provision of protective gear, facilities, and training. They also contended that regular City employees received more favorable treatment and a better grievance procedure. The Supreme Court initially granted plaintiffs' motion for injunctive relief and class certification, while denying defendants' cross-motion to dismiss. However, the Appellate Division reversed this decision, dismissing the complaint on procedural grounds due to the plaintiffs' failure to exhaust administrative remedies as required by the Public Employee Safety and Health Act (Labor Law § 27-a) and the Social Services Law. The court emphasized that administrative agencies have exclusive original jurisdiction over such matters, and judicial review is only permissible after administrative channels have been exhausted. The preliminary injunction was also found to be improperly granted due to a lack of factual findings.