M.G.M. Insulation, Inc. v. Gardner
R-J Taylor General Contractors, Inc. and its subcontractors challenged a determination by the Department of Labor's Bureau of Public Work, which found their fire station construction project subject to prevailing wage requirements under Labor Law § 220. The Bureau concluded that the Bath Volunteer Fire Department (BVFD), despite being a not-for-profit corporation, functioned as a municipal department, and the fire station construction was a public work project. Petitioners initiated a CPLR article 78 proceeding to challenge this determination. The court affirmed the Department of Labor's finding, concluding there was substantial evidence that BVFD was the functional equivalent of a municipal corporation and that the project served a public benefit. Consequently, the prevailing wage requirements were applicable, and the petition was dismissed.