Matter of Colon (Pd 10276, Inc.--Commissioner of Labor)
Nicanor Colon filed for unemployment insurance benefits after ceasing operation of his cleaning business, leading the Department of Labor to assess PD 10276, Inc., doing business as Jan-Pro Cleaning Systems of the Hudson Valley, for additional unemployment insurance contributions. An Administrative Law Judge initially ruled Colon an independent contractor, but the Unemployment Insurance Appeal Board reversed this decision, finding Colon and similarly situated individuals to be employees. PD 10276, Inc. appealed the Board's decision to the Appellate Division, Third Department. The Appellate Division affirmed the Board's determination, concluding that there was substantial evidence of an employment relationship based on the indicia of control exercised by Jan-Pro Cleaning over its unit franchisees, similar to findings in prior cases like Matter of Baez. The court highlighted requirements like certification, provision of supplies, periodic inspections, and noncompetition clauses as supporting the Board's conclusion.