Hart v. Holtzman
This case involves a CPLR article 78 petition challenging a determination made by the Comptroller of the City of New York. The Comptroller had ruled that rehabilitation and construction work on the Greenpoint Hospital site, despite being publicly financed, was for privately-owned and constructed housing for low-income tenants, thus not constituting "public works" under New York State Labor Law § 220. Consequently, the Comptroller determined that workers on these projects were not entitled to prevailing wages. The Supreme Court affirmed the Comptroller's decision, finding it had a rational basis and was neither arbitrary nor capricious. The appellate court further affirmed, emphasizing that the primary objective of the work, not incidental public benefit or significant governmental funding, determines if a project is a "public work" subject to prevailing wage requirements, especially when private developers retain ownership and construction risk.