Ramaglia v. New York State Department of Transportation
Petitioners, including union representative Joseph Ramaglia, requested payroll records from a steel company under the Freedom of Information Law (FOIL) through the Department of Transportation (DOT). They sought to determine if the steel company, a contractor for overpass replacement on the Long Island Expressway, was violating prevailing wage laws. DOT denied the request, stating it neither possessed nor was required to collect these records, as the steel company was merely a materials supplier, not directly involved in public works construction. Petitioners commenced a CPLR article 78 proceeding to compel DOT to obtain and produce the records. The Supreme Court dismissed their application, agreeing that DOT had no obligation to the supplier's records. On appeal, the court affirmed, ruling that the prevailing wage law does not apply to contracts for the sale of goods, even custom or shop-finished products, especially when such work is a normal part of manufacturing and not typically done on-site.