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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Nov 10, 1982

American Broadcasting Companies, Inc. v. Roberts

ABC, a telecommunications company, was cited for violating Labor Law § 162(3) for not providing a second meal period to employees working specific shifts. ABC challenged the violation, arguing the law did not apply to their industry or skilled workers, and that their collective bargaining agreement waived or substantially complied with the requirement. The Industrial Board of Appeals affirmed the violation, but Special Term annulled this decision, concluding that employees could waive the statutory meal period benefit through their labor contracts. The current court's majority affirmed Special Term's judgment. A dissenting opinion argued that Labor Law § 162(3) is a public policy health measure designed for worker protection and therefore cannot be waived by private agreements or collective bargaining, emphasizing that the statute's 'every person' language applies broadly.

Labor LawMeal PeriodsWaiver of Statutory RightsCollective Bargaining AgreementPublic PolicyTelecommunications IndustryIndustrial CommissionerIndustrial Board of AppealsAppellate ReviewDissenting Opinion
References
19
Case No. MISSING
Regular Panel Decision

Gordon v. Kaleida Health

Six plaintiffs, including registered nurses and respiratory therapists, initiated a putative collective/class action against Kaleida Health and its associated entities. They alleged violations of the Fair Labor Standards Act and New York Labor Law concerning unpaid wages, overtime, and improper meal break deductions. The court addressed four motions: plaintiffs' class certification requests for meal break and rounding policies, and both parties' summary judgment motions. The judge denied all of the plaintiffs' motions and granted the defendants' motions, striking the rounding class certification, denying the meal break class certification, and largely granting summary judgment to Kaleida regarding certain NYLL claims for three plaintiffs. The court found no evidence of a uniform system-wide policy for wage violations and upheld the employer's right to delegate reporting procedures for missed meal breaks.

Fair Labor Standards ActNew York Labor LawClass ActionWage and Hour DisputeOvertime PayMeal Break PolicyRounding PolicySummary JudgmentClass CertificationHourly Employees
References
59
Case No. MISSING
Regular Panel Decision

Capital Newspapers Division—The Hearst Corp. v. Hartnett

This CPLR Article 78 proceeding involved a petitioner challenging a determination by the Industrial Board of Appeals, which found the petitioner guilty of violating Labor Law § 162 (4) concerning meal periods for night shift pressmen. The petitioner unilaterally advanced the meal period window, prompting a complaint from the Pressmen's Union. The Industrial Board of Appeals upheld the violation, rejecting the petitioner's argument that the statutory requirement could be waived. Citing precedent from Matter of American Broadcasting Cos. v Roberts, this court found that the Board erred in concluding that the statute's purpose precluded any waiver or modification of meal period terms. Consequently, the court annulled the determination and remitted the matter to the Industrial Board of Appeals to determine if a valid waiver, freely and knowingly made, had occurred.

Labor LawMeal PeriodCollective Bargaining AgreementWaiver of Statutory RightsAdministrative ReviewIndustrial Board of AppealsCPLR Article 78Judicial ReviewEmployer-Employee RelationsPressmen's Union
References
9
Case No. MISSING
Regular Panel Decision
Nov 29, 2011

Hamelin v. Faxton-St. Luke's Healthcare

Plaintiffs Dawn Hamelin, Rakiesha Griffin, and Julie Flint brought a collective action against Faxton-St. Luke’s Healthcare and other entities, alleging violations of the FLSA, ERISA, and NYLL related to uncompensated meal breaks and pre/post-shift work. The court granted defendants' motion for partial summary judgment, dismissing eight opt-in plaintiffs who did not claim to have worked through meal breaks without compensation. Plaintiffs' motion for class certification was granted for Subclass I, the 'Meal Break Deduction Class,' finding that common questions predominated and a class action was the superior method. However, certification was denied for Subclass II (pre/post-shift work) due to lack of commonality predominance and Subclass IV (ERISA claims) due to insufficient evidence. The court also appointed Thomas & Solomon LLP as class counsel.

Fair Labor Standards ActEmployee Retirement Income Security ActNew York Labor LawClass ActionCollective ActionMeal Break DeductionsUnpaid WagesSummary JudgmentClass CertificationRule 23
References
57
Case No. MISSING
Regular Panel Decision

Fengler v. Crouse Health Foundation, Inc.

The case involves two named plaintiffs, Michelle Fengler and Marianne Meyers, along with over a hundred other employees, who allege that Crouse Health Hospital, Inc. violated the Fair Labor Standards Act by failing to properly compensate hourly employees due to an automatic meal break deduction policy. Plaintiffs contend that chronic understaffing and patient care demands required employees to work during meal breaks without pay. The court, presided over by Magistrate Judge David E. Peebles, granted preliminary certification for a collective action, but limited the class to current and former hourly employees of Crouse Hospital with direct patient care responsibilities who were subject to automatic meal break deductions and worked through unpaid breaks in the last three years. The court also partially granted discovery requests for employee names and addresses, while denying requests for more private information, and ordered the parties to agree on a notice for potential opt-in plaintiffs.

Fair Labor Standards ActCollective ActionMeal Break DeductionUnpaid WagesHourly EmployeesPatient Care ResponsibilitiesPreliminary CertificationWage and Hour DisputeUnderstaffingJudicial Discretion
References
24
Case No. MISSING
Regular Panel Decision

Meyers v. Crouse Health System, Inc.

Named plaintiff Marianne Meyers brought this action against Crouse Health Hospital, Inc. and other entities, alleging violations of FLSA, ERISA, and NYLL regarding uncompensated work time, specifically concerning automatic meal break deductions and other pay policies. Defendants moved for partial summary judgment to dismiss eight opt-in plaintiffs from the FLSA collective action, while plaintiff moved to certify NYLL and ERISA claims as a class action. The court granted defendants' motion, dismissing seven opt-in plaintiffs who admitted they did not work through meal breaks without compensation, finding them outside the conditionally certified FLSA class. The court also granted class certification for Subclass I (Meal Break Deduction Class) under Rule 23(b)(3) but denied certification for Subclass II (Pre and Postliminary Work Class) due to a lack of numerosity, and for Subclass IV (ERISA Class) due to insufficient evidence. Thomas & Solomon LLP was appointed as class counsel for Subclass I, and the matter was referred back to Magistrate Judge David Peebles for further pretrial proceedings, with the court also affirming the exercise of supplemental jurisdiction over the NYLL claims.

FLSA Collective ActionERISA Class ActionNYLL Wage and HourClass CertificationMeal Break DeductionsUncompensated WorkSummary Judgment GrantedSupplemental JurisdictionRule 23 PrerequisitesNumerosity Challenge
References
55
Case No. MISSING
Regular Panel Decision

Luna v. American Airlines

Plaintiff Monserrate Luna sued American Airlines and LSG Sky Chefs for alleged injuries from a contaminated meal. Defendants impleaded Overhill Farms, Inc., the meal supplier, for indemnification. Following a jury verdict in favor of the defendants in the primary lawsuit, the court addressed the third-party indemnification claims. The court dismissed all common-law indemnification claims and LSG Sky Chefs' contractual indemnification claim. However, American Airlines' contractual indemnification claim against Overhill Farms, Inc. was granted, limited to expenses incurred in defending against Luna's initial lawsuit, and excluding costs for pursuing indemnification from Overhill Farms itself.

IndemnificationContractual IndemnificationCommon-Law IndemnificationThird-Party ClaimsAirline LiabilityProduct LiabilityFood ContaminationAttorney's FeesLitigation ExpensesSubrogation
References
39
Case No. MISSING
Regular Panel Decision
Apr 14, 1980

In re the Claim of Cruz

The claimant, an assistant engineer at a nursing home, was discharged for leaving the premises for a meal break in violation of employer policy, despite a prior warning. The employer required the claimant to remain on-site during breaks as he worked alone on a night shift and needed to be available for emergencies. The Unemployment Insurance Appeal Board initially found the employer's rule invalid based on its interpretation of Labor Law § 162 (subd 4), determining the claimant's actions did not constitute disqualifying misconduct. However, the Appellate Division reversed this decision, holding that Labor Law § 162 (subd 4) does not dictate the location of a meal break and that the employer's policy, especially with compensated breaks, was reasonable. The case was remitted to the Board for further proceedings.

MisconductUnemployment InsuranceMeal Break PolicyEmployer RulesStatutory InterpretationLabor LawAdministrative Law JudgeAppeal BoardNursing Home EmployeeTermination
References
4
Case No. MISSING
Regular Panel Decision

Consolidated Rail Corp. v. Hudacs

This case concerns a railroad corporation challenging a notice of violation from the Department of Labor for not providing meal periods to its yardmasters as mandated by Labor Law § 162. The Industrial Board of Appeals (IBA) upheld the violation, prompting the petitioner to initiate a CPLR article 78 proceeding. After the Supreme Court dismissed the petition, an appeal ensued. The core legal questions revolved around whether the Federal Railway Labor Act (RLA) preempts the enforcement of Labor Law § 162 and if the yardmasters had waived their state law protections. The court ultimately ruled that the RLA does not preempt the state law, as its enforcement does not require interpretation of the collective bargaining agreement. Furthermore, any purported waiver of meal period rights in the collective bargaining agreement was deemed invalid, as it undermined the fundamental legislative intent of Labor Law § 162 to ensure worker health and safety.

PreemptionRailway Labor ActLabor LawMeal PeriodsCollective Bargaining AgreementWaiverYardmastersState LawFederal LawIndustrial Board of Appeals
References
8
Case No. MISSING
Regular Panel Decision

McGlone v. Contract Callers, Inc.

Plaintiff Michael McGlone initiated a Fair Labor Standards Act (FLSA) action against Contract Callers, Inc. (CCI), Michael McGuire, and William Tim Wertz, alleging unpaid overtime for work performed before and after recorded workdays and during meal breaks. McGlone sought conditional certification for a nationwide collective action of Field Service Representatives (FSRs), asserting a common policy of wage violations, including uncompensated preparatory and concluding tasks, and automatic meal break deductions despite working through them. The court applied a two-step analysis for FLSA collective actions, focusing on the lenient "notice stage" standard. While the plaintiff claimed company-wide misconduct, his evidence for a nationwide class was deemed insufficient, relying primarily on "information and belief." Consequently, the court denied conditional certification for a nationwide class but granted it for FSRs employed in CCI's New York Division, where McGlone demonstrated direct personal knowledge of the alleged violations and supervisory directives. Additionally, the statute of limitations was equitably tolled as of the motion's filing date due to the court's processing time.

FLSACollective ActionConditional CertificationOvertime PayWage ViolationsMeal BreaksUncompensated WorkField Service RepresentativesEquitable TollingNew York Division
References
28
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