Gress v. Brown
Plaintiffs, seasonal sanitation employees of the City of Buffalo, initiated a class action alleging that the City and Mayor Byron Brown failed to pay them in accordance with the Buffalo Living Wage Ordinance. Defendants, including the Buffalo Fiscal Stability Authority (BFSA), appealed a judgment that granted plaintiffs partial summary judgment, declaring the BFSA lacked authority to freeze their wages. The court rejected defendants' argument that the action was a CPLR article 78 proceeding, thus a four-month statute of limitations did not apply, finding the action primarily sought damages for wage violations. It further affirmed that the BFSA's wage freeze was inapplicable to plaintiffs because their wage increases stemmed from the Living Wage Ordinance, not a collective bargaining agreement, placing them outside the BFSA's authority.