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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Rios v. Altamont Farms, Inc.

The plaintiffs, migrant farm workers, sought to enforce a Puerto Rican default judgment against Altamont Farms, Inc., a New York apple grower. Altamont contended that the Puerto Rican court lacked personal jurisdiction. Justice Lawrence E. Kahn, presiding in New York, determined that Altamont's voluntary filing of a job offer through the Federal Interstate Clearance System, which was transmitted to Puerto Rico for labor recruitment, established sufficient minimum contacts. The court ruled that Altamont's actions satisfied Puerto Rico's long-arm statute and met due process standards, thereby subjecting it to Puerto Rican jurisdiction. Consequently, the New York court granted the plaintiffs' motion to enforce the judgment under full faith and credit principles and also ordered the consolidation of related cases.

Personal JurisdictionFull Faith and CreditLong-Arm StatuteMinimum ContactsDue ProcessWagner-Peyser ActMigrant Farm WorkersDefault Judgment EnforcementInterstate Clearance SystemJudicial Consolidation
References
9
Case No. 2021 NY Slip Op 00461
Regular Panel Decision
Jan 28, 2021

Matter of Executive Cleaning Servs. Corp. v. New York State Dept. of Labor

Executive Cleaning Services Corporation and Cef Saiz, the petitioners, challenged a determination by the Commissioner of Labor, alleging they failed to pay prevailing wages for cleaning services provided to the Ossining Public Library. The Department of Labor initiated an investigation following an employee complaint and concluded that the contract was subject to the prevailing wage provisions of Labor Law article 9. Petitioners argued the library was not a 'public agency' as defined by Labor Law § 230 (3), thus exempting their contract from prevailing wage requirements. The Appellate Division, Third Department, ultimately agreed with the petitioners, finding that despite its public function and ties to the school district, the Ossining Public Library does not fit the statutory definition of a public agency under Labor Law § 230 (3). Consequently, the Commissioner's determination was annulled, the petition granted, and the action for declaratory judgment severed and remitted to the Supreme Court.

Prevailing Wage LawLabor Law Article 9Public Agency DefinitionOssining Public LibraryEducation CorporationCPLR Article 78 ProceedingDeclaratory Judgment ActionBuilding Service ContractsSchool District Public LibraryAdministrative Law
References
18
Case No. 2024 NY Slip Op 01944 [226 AD3d 836]
Regular Panel Decision
Apr 10, 2024

Ragusa v. Drazie's Farm II, LLC

The plaintiff, Matthew Ragusa, appealed an order denying his cross-motion to amend the complaint to add Drazie's Farm, LLC as a defendant and granting summary judgment to Drazie's Farm II, LLC on a Labor Law § 240 (1) claim. The Appellate Division, Second Department, affirmed the lower court's decision. The court found that the relation-back doctrine did not apply because Drazie's Farm II, LLC and Drazie's Farm, LLC were separate entities with potentially different defenses, thus not united in interest. Furthermore, Drazie's Farm II, LLC established that it did not own the property where the accident occurred and therefore could not be held liable under Labor Law § 240 (1).

Personal injuryLabor Law § 240 (1)A-frame ladderfall from heightpremises liabilityrelation-back doctrinesummary judgmentlimited liability companyproperty ownershipadjoining properties
References
10
Case No. MISSING
Regular Panel Decision

Fraternal Order of Police, National Labor Council, USPS No. 2 v. United States Postal Service

The Fraternal Order of Police (FOP) and 13 individual Postal Police Officers sued the United States Postal Service and its employees, alleging violations of federal and state law, as well as their employment contract. Plaintiffs challenged restrictions on their law enforcement authority, citing 40 U.S.C. § 318, and also claimed illegal locker searches under the Fourth Amendment and New York law. The defendants sought dismissal, primarily arguing a lack of subject matter jurisdiction and the plaintiffs' failure to exhaust administrative remedies. The court granted the defendants' motion, dismissing the claims. It ruled that Section 318 does not confer a private right of action and that the plaintiffs failed to exhaust the grievance procedures outlined in their collective bargaining agreement and the Postal Reorganization Act for their search and contract-related claims.

Labor LawPostal ServicePolice PowersFourth AmendmentLocker SearchCollective Bargaining AgreementExhaustion of RemediesPrivate Right of ActionSubject Matter JurisdictionMotion to Dismiss
References
51
Case No. 2022 NY Slip Op 00229
Regular Panel Decision
Jan 13, 2022

Matter of Patsis (Legal Interpreting Servs., Inc.--Commissioner of Labor)

The case concerns an appeal by Legal Interpreting Services, Inc. (LIS) from a decision of the Unemployment Insurance Appeal Board. The Board had ruled that Louiza Patsis, a linguist working for LIS, was an employee and that LIS was liable for unemployment insurance contributions. LIS contended that Patsis was an independent contractor and challenged the Board's adherence to Department of Labor guidelines. The Appellate Division, Third Department, affirmed the Board's decision, finding substantial evidence supported the finding of an employment relationship. The court noted the control LIS exercised over its linguists through a written agreement and job assignments, and found no inconsistency with the Department of Labor guidelines.

unemployment insuranceemployment relationshipindependent contractorappellate divisionlabor lawunemployment benefitsstatutory interpretationsubstantial evidenceadministrative reviewlegal interpreting
References
7
Case No. MISSING
Regular Panel Decision

Tri-State Employment Services, Inc. v. Mountbatten Surety Co.

The United States Court of Appeals for the Second Circuit certified a question to the New York Court of Appeals regarding whether a professional employer organization (PEO) may be a proper claimant under a labor and materials surety bond. Plaintiff Tri-State Employment Services, Inc., a PEO, provided employee leasing services to Team Star Contractors, Inc. for a construction project, covering payroll, taxes, and insurance. When Team Star failed to pay, Tri-State filed a claim with the surety, Mountbatten Surety Company, Inc., which was dismissed by the District Court. The New York Court of Appeals determined that a PEO's primary role as an administrative services provider and payroll financier creates a presumption that it does not provide labor for the purpose of a payment bond claim. The Court found that Tri-State failed to overcome this presumption by demonstrating sufficient direction and control over the workers. Consequently, the Court answered the certified question in the negative, ruling that Tri-State Employment Services, Inc. is not a proper claimant under the surety bond in the circumstances presented.

Professional Employer OrganizationSurety BondLabor and Materials BondClaimant StatusEmployee LeasingPayroll ServicesAdministrative ServicesConstruction ContractCertified QuestionNew York Law
References
16
Case No. 2013-2706 Q C
Regular Panel Decision
Sep 19, 2016

NYS Acupuncture, P.C. v. State Farm Mut. Auto. Ins. Co.

This case, NYS Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co., concerned an appeal from an order of the Civil Court of the City of New York, Queens County. The plaintiff, NYS Acupuncture, P.C., sought assigned first-party no-fault benefits from State Farm, which had moved for summary judgment arguing full payment according to the workers' compensation fee schedule. The Civil Court initially granted State Farm's motion. On appeal, NYS Acupuncture, P.C. contended that the fee schedule reductions were improper. The Appellate Term, Second Department, affirmed the prior ruling, finding that State Farm adequately demonstrated it had fully compensated the plaintiff for acupuncture services based on the applicable workers' compensation fee schedule for services performed by chiropractors, referencing Great Wall Acupuncture, P.C. v Geico Ins. Co.

Workers' Compensation Fee ScheduleNo-Fault BenefitsAcupuncture ServicesChiropractorsSummary JudgmentAppellate ReviewInsurance DisputeFee Schedule ReductionAssigned BenefitsMedical Billing
References
1
Case No. MISSING
Regular Panel Decision

M. Cristo, Inc. v. State of New York Office of General Services

This dissenting opinion by Staley, Jr., J. concerns the rejection of a low bid from a petitioner by the Office of General Services. The rejection was based on the petitioner's unresolved labor dispute with Laborers Local No. 190, which the Office of General Services feared would cause disruption and delay to the South Mall project, a 'time of the essence' contract. Staley, Jr., J. argues that the State's action was lawful, citing State Finance Law § 174 and previous cases that permit bid rejection in the best interests of the State, especially when a labor dispute threatens project completion. The dissent distinguishes this case from precedents involving mere threats of union action. However, the majority decision, which this opinion dissents from, reversed the judgment and ruled in favor of the petitioner.

Labor DisputeBid RejectionState ContractPublic WorksTime of EssenceJudicial ReviewAppellate DecisionProcurement LawNonunion WorkersProject Delay
References
3
Case No. MISSING
Regular Panel Decision

Volt Technical Services Corp. v. Immigration & Naturalization Service

Plaintiff Volt Technical Services Corp. applied for H-2 visas for nuclear start-up technicians, which the Immigration and Naturalization Service (INS) denied, asserting the need was permanent, not temporary. After the denial was affirmed on appeal, Volt filed suit, alleging the INS's decision was arbitrary and capricious. The court upheld the INS's interpretation of the Immigration and Nationality Act § 101(a)(15)(H)(ii), which requires the employer's need for services to be temporary, not just the individual assignments. Finding that Volt demonstrated a recurring need for such technicians over several years, the court granted the INS's motion for judgment on the pleadings and denied Volt's.

Immigration LawH-2 visasNonimmigrant WorkersTemporary EmploymentImmigration and Nationality ActAdministrative Procedures ActDeclaratory Judgment ActAgency InterpretationJudicial ReviewNuclear Industry
References
5
Case No. MISSING
Regular Panel Decision

Sage Realty Corp. v. ISS Cleaning Services Group, Inc.

Plaintiffs, consisting of the owners of six commercial buildings and their managing agent, Sage Realty Corporation, brought an antitrust claim against the Realty Advisory Board on Labor Relations, Inc. (RAB) and ISS Cleaning Services Group, Inc. (ISS). The plaintiffs alleged that during a 1996 office building maintenance employee strike in New York City, the defendants engaged in a group boycott. This boycott purportedly blocked union members from returning to work for certain cleaning service contractors, thereby preventing plaintiffs from employing those union members. The defendants moved to dismiss the complaint, arguing that the plaintiffs failed to allege a cognizable antitrust injury and that the non-statutory labor exemption barred the claim. The court granted the defendants' motion, concluding that the plaintiffs did not sufficiently demonstrate antitrust injury and that the defendants' conduct was protected by the non-statutory labor exemption.

Antitrust LawGroup BoycottLabor ExemptionCollective BargainingLabor StrikeCleaning Service IndustryCommercial Real Estate MarketMotion to DismissSherman ActNon-Statutory Labor Exemption
References
21
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