Acme American Refrigeration, Inc. v. New York City Department of Education
The petitioners, Acme American Repairs, Inc. and Acme American Refrigeration, Inc., initiated a CPLR article 78 proceeding challenging publicly bid contracts awarded by the New York City Department of Education (DOE) for the repair of cafeteria and kitchen equipment. They contended that these contracts constituted 'public work' under Labor Law § 220, mandating a prevailing wage schedule in the bid solicitation, which was absent. Petitioners argued this omission created a competitive disadvantage, as they purportedly based their bids on union-scale rates. The respondents moved to dismiss the petition as time-barred, asserting that the four-month statute of limitations began when petitioners became aware of the bid specification's contents (October/November 2010), not upon contract award (January 2011). The court granted the dismissal, ruling the petition was time-barred as the injury accrued when petitioners knew or should have known of the bid solicitation's contents.