State v. Consolidated Edison Co. of New York, Inc.
The Attorney-General of New York initiated an action against Consolidated Edison of New York (Con Ed) seeking civil damages and an injunction to enforce compliance with the Right to Know Law (Public Health Law art 48; Labor Law art 28). This law mandates employers to provide information and training to employees concerning toxic substances in the workplace. Con Ed moved to dismiss the action, presenting two main arguments: first, that the Attorney-General lacked authority to sue without a prior investigation and determination by the Department of Labor, and second, that primary jurisdiction over enforcement of the Right to Know Law rested with the Department of Labor and the Department of Health. The court denied Con Ed's motion on both counts, ruling that Labor Law § 882 (1) unambiguously grants the Attorney-General the authority to bring such actions without a prerequisite administrative investigation. Furthermore, the court found that the doctrine of primary jurisdiction did not apply, as the administrative agencies had not yet promulgated comprehensive regulations to enforce the law, leaving a regulatory void that the judiciary was empowered to address to protect employee rights.