People v. 14 West Garment Factory Corp.
This case concerns a special proceeding initiated by Eliot Spitzer, Attorney General of the State of New York, seeking injunctive relief against apparel manufacturers and contractors, 14 West Garment Factory Corp. and Ding and Mag Fashion, Inc. The petitioner alleged that the respondents were producing and selling 'hot goods' in violation of Labor Law articles 6 and 19, pertaining to wage payment and minimum wage. The court had previously issued a temporary restraining order, and the current opinion addresses the petitioner's motion for a preliminary injunction and 14 West's cross-motion to dismiss. Justice Alice Schlesinger granted the preliminary injunction and denied the motion to dismiss, affirming the strict liability of manufacturers and contractors under the 'hot goods' law, distinct from retailers who have a good-faith exception. The court emphasized the remedial purpose of the statute to protect workers from underpayment and to prevent illicit profits from illegal labor.