Matter of Fleetwood Drywall Inc. (Commissioner of Labor)
Fleetwood Drywall Inc. appealed a decision from the Unemployment Insurance Appeal Board, which found them liable for additional unemployment insurance contributions for certain drywall installers and finishers. Fleetwood considered these workers independent contractors, but an audit and subsequent hearings determined an employment relationship existed under the Construction Industry Fair Play Act (Labor Law art 25-B). The Administrative Law Judge and the Board found that Fleetwood failed to rebut the statutory presumption of an employment relationship by not meeting all 12 statutory criteria for separate business entities under Labor Law § 861-c (2). The Appellate Division affirmed the Board's decision, specifically finding that Fleetwood failed to demonstrate that the subcontractors owned the capital goods (drywall) as required by the statute.