Vulcan Affordable Housing Corp. v. Hartnett
This CPLR article 78 proceeding addresses whether a low-income housing project in the City of Albany, partially funded by a grant from the Affordable Housing Corporation (AHC), qualifies as a "public works" project under Labor Law § 220, which would necessitate the payment of prevailing wages. The petitioner, a private contractor engaged in building the housing units, refused an administrative subpoena for payroll information, asserting Labor Law § 220 was inapplicable. The project involved construction of low- and moderate-income housing, with title held by Capital City Housing Development Fund Company (CCH), and no public ownership, access, or use of the structures. Supreme Court concluded, and the appellate court affirmed, that the project did not meet the criteria for a "public works" project despite serving a public function of neighborhood rehabilitation, distinguishing it from fully subsidized public housing. Consequently, the subpoena duces tecum seeking payroll information was quashed.