P & T Iron Works v. Talisman Contracting Co.
P&T Iron Works (P&T), a subcontractor, sued Talisman Contracting Co., Inc. (Talisman), a general contractor, for non-payment on a New York City Housing Authority project. Talisman asserted an affirmative defense claiming P&T failed to pay its employees prevailing wages under Labor Law § 220(3). The Supreme Court, Suffolk County, granted P&T's motion to strike this defense. The appellate court affirmed the decision, ruling that no private right of action for underpayment of wages exists under Labor Law § 220 without a prior administrative determination in the employee's favor. The court further noted that such an action belongs solely to the underpaid employees and that determination of prevailing wage claims is the exclusive initial province of the fiscal officer in an administrative proceeding, thus Talisman lacked standing.