Nash v. New York State Department of Labor
Petitioner, a self-employed electrician and sole proprietor, was found by the Commissioner of Labor to have willfully underpaid prevailing wages and supplements to employees on two public works projects. An investigation by the Department of Labor and a subsequent hearing confirmed that petitioner's employees, despite lacking apprentice registration, performed work classified as journeyman electrician duties and were underpaid by significant amounts. The Hearing Officer's recommendation that the underpayment be found willful, with interest and a civil penalty, was adopted by the Commissioner. Petitioner initiated a CPLR article 78 proceeding to review this determination. The court confirmed the Commissioner's determination, finding substantial evidence supported both the employee classification and the finding of willfulness, and rejected petitioner's constitutional arguments.