Cromwell v. New York City Health & Hospitals Corp.
Plaintiff Jerome Cromwell sued the New York City Health and Hospitals Corporation (HHC) and its CEO, Alan D. Aviles, alleging unpaid wages for work performed before and after scheduled shifts and during breaks. Cromwell sought overtime and gap-time pay under both the Fair Labor Standards Act (FLSA) and New York Labor Law (NYLL). Defendants moved to dismiss the NYLL claims, asserting that HHC is a political subdivision of New York State and therefore exempt from NYLL wage provisions. The Court conducted a particularized inquiry into HHC's nature, considering its essential public function, substantial public funding, and classification as a public employer under other state and federal laws. Ultimately, the Court granted the defendants' motion, ruling that HHC is a political subdivision for NYLL purposes and dismissing Cromwell's NYLL claims with prejudice.