Williams v. AGK Communications, Inc.
The court addresses whether severance pay for an executive constitutes 'wages' under New York Labor Law for purposes of awarding attorney's fees and liquidated damages. Following a nonjury trial, plaintiff James K. Williams was awarded $25,000 in severance pay from defendant WAQX. Williams then sought additional remedies under Labor Law § 198 (1-a), arguing his salary fell within the definition of wages. The court distinguished between 'wages' for manual labor and 'salary' for higher-level employment, referencing the historical 'Stryker' distinction and definitions within Labor Law §§ 190 and 191. Concluding that Williams, as an executive, received salary and not wages, the court determined he was not covered by Article 6 of the Labor Law. Consequently, Williams' motion for attorney's fees and liquidated damages was denied.