City of New York v. Commissioner of Labor
Petitioners, the City of New York and the Department of Juvenile Justice (DJJ), along with three juvenile detention centers, initiated a proceeding to annul a 2010 decision by the State Industrial Board of Appeals. This decision upheld 2007 notices of violations (NOVs) issued against the centers for exposing employees to workplace violence, citing Labor Law § 27-a (3), the General Duty Clause. Petitioners argued the NOVs should have cited the more specific Workplace Violence Prevention Act (WVPA), Labor Law § 27-b. Respondents, District Council 37, the Commissioner of Labor, and the Board, contended that the WVPA could not be cited as its implementing regulations were not yet promulgated. The court, finding the Board's decision rational and consistent with statutory and regulatory schemes regarding "specific standards" under PESHA, denied the petition and dismissed the CPLR article 78 proceeding.