Joint Apprenticeship & Training Council of Local 363 v. New York State Department of Labor
The plaintiff, Joint Apprenticeship and Training Council of Local 363 (JATC), sought a preliminary injunction to prevent the New York State Department of Labor (NYSDOL) from deactivating its status as a registered apprenticeship training program. JATC argued that deactivation procedures should mirror deregistration, requiring a hearing, and that the Fitzgerald Act provided a private right of action. The court denied the motion, finding no federal requirement for a hearing for deactivation and distinguishing it from deregistration, which has more severe consequences. Furthermore, the court concluded that the Fitzgerald Act does not create a private right of action for program sponsors. The court also found no irreparable harm to the plaintiff or its apprentices, as apprentices could transfer to other programs without losing credit, and the JATC program could re-register or continue unregistered.