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Case Law Database

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

Case No. MISSING
Regular Panel Decision
Jul 07, 2003

Cuevas v. Americorps

This case involves an appeal from a Workers' Compensation Board decision that found a claimant's workers' compensation claim was not preempted by federal law. The claimant, a participant in the Americorps program through the Red Hook Public Safety Corps, sustained back and neck injuries while performing community gardening. The Workers' Compensation Board determined she was a general employee of the Fund for the City of New York, Inc. (FCNY) and a special employee of Americorps. FCNY and its carriers appealed, arguing that 42 USC § 12511 explicitly preempts state law by stating that Americorps participants are not employees for the purposes of that subchapter. The court affirmed the Board's decision, concluding that the federal statute's definition of 'participant' as 'not an employee' was limited to the purposes of the federal subchapter and did not dictate employee status for state workers' compensation benefits. The court further noted that 42 USC § 12594 (b) contemplates states treating participants as employees for workers' compensation purposes, reinforcing the lack of preemptive intent.

Federal preemptionAmericorps programEmployment status determinationStatutory interpretationFund for the City of New YorkCommunity service injuryWorkers' Compensation Board appealAppellate review42 USC 1251142 USC 12594
References
4
Case No. MISSING
Regular Panel Decision

Betts v. University of Rochester

The Special Term's decision to grant the defendant's motion to dismiss the plaintiff's complaint on the grounds of lack of subject matter jurisdiction was unanimously reversed. The primary issue on appeal was whether the causes of action presented in the complaint were preempted by the National Labor Relations Act. The court determined that the plaintiff's first and second causes of action, alleging wrongful termination in violation of an employment contract, were not preempted, as the defendant's alleged anti-union animus was irrelevant to the breach of contract claim. Additionally, the plaintiff's third cause of action, involving defamation and/or intentional infliction of emotional distress, was also found not to be preempted, as these claims are considered of peripheral concern to federal labor law and do not constitute unfair labor practices.

Wrongful TerminationBreach of Employment ContractDefamationIntentional Infliction of Emotional DistressNational Labor Relations ActLabor Law PreemptionSubject Matter JurisdictionAppellate ReviewState Court JurisdictionAnti-Union Animus
References
8
Case No. MISSING
Regular Panel Decision

General Electric Co. v. New York State Department of Labor

General Electric (GE) challenged New York’s prevailing wage law (N.Y.Lab.Law § 220), seeking its invalidation and an injunction against enforcement. The court previously denied GE's preliminary injunction, but the Second Circuit vacated that decision, ruling that Section 220's "supplements" provisions were preempted by ERISA and remanding for a determination on unconstitutional delegation. Both GE and the State moved for summary judgment. The court found the wage provisions of Section 220 severable from the preempted supplement provisions and that non-ERISA supplement provisions were not implicitly preempted. GE's equal protection and delegation challenges were rejected. Consequently, GE's motion for summary judgment was denied, and the defendants' motion for summary judgment was granted for counts one, three, four, and five of the complaint.

ERISA PreemptionNLRA PreemptionNew York Prevailing Wage LawStatutory SeverabilityUnconstitutional DelegationDue ProcessEqual ProtectionSummary JudgmentFederal Court JurisdictionEleventh Amendment
References
28
Case No. MISSING
Regular Panel Decision
Dec 19, 1985

Sasso v. Vachris

The New York Court of Appeals addressed whether Business Corporation Law § 630, which allows employees to recover unpaid pension and welfare contributions from the 10 largest shareholders of a closely held corporation, is preempted by ERISA. Plaintiffs, trustees of a union welfare and pension trust fund, sought to collect delinquent contributions from shareholders of Vacar Construction Company after the corporation filed for bankruptcy. The lower courts had ruled that the state law was preempted by ERISA. The Court of Appeals reversed this decision, holding that Business Corporation Law § 630 serves as a remedial enforcement mechanism for collecting overdue contributions and does not regulate the terms or conditions of employee benefit plans. The court clarified that ERISA's preemption clause has inherent limits, and state laws with only a "tenuous, remote, or peripheral" effect on benefit plans are not preempted.

ERISA PreemptionShareholder LiabilityDelinquent ContributionsEmployee Benefit PlansMultiemployer PlansCollective BargainingState Law RemediesBusiness Corporation LawTrust FundsPension Funds
References
19
Case No. MISSING
Regular Panel Decision
Mar 26, 1996

City of New York v. Job-Lot Pushcart

This case addresses whether New York City's Administrative Code § 10-131 (g), which imposes strict regulations on the sale and use of toy guns, is preempted by the 1988 Federal Toy Gun Law (15 USC § 5001). The City initiated an action against defendants, including JA-RU, Inc., for distributing toy guns that violated the local ordinance's color, trade name, and barrel plug requirements. Defendants argued that the Federal law, which sets its own marking standards, preempted the City's stricter regulations. The New York Court of Appeals affirmed the lower courts' denial of preemption, ruling that Congress did not intend to expressly or impliedly preempt all local regulation of toy gun markings. The Court found that the Federal law's preemption clause is limited, and that compliance with both Federal and City regulations is possible and aligns with the public safety objectives of both statutes, as the City's law is not inconsistent with the Federal statute.

PreemptionFederal LawLocal LawToy GunsAdministrative CodePublic SafetyStatutory InterpretationSupremacy ClausePolice PowersNew York City
References
27
Case No. MISSING
Regular Panel Decision

MacK v. Metro-North Commuter Railroad

Plaintiff Sharon Mack initiated an action in New York State Supreme Court against Metro-North Commuter Railroad and employees Maurice Kiniry and Joe Bauman, alleging state law claims of defamation, assault, unlawful imprisonment, and intentional infliction of mental anguish on behalf of herself and her son. Defendants removed the case to federal court, arguing that the claims were preempted by the Railway Labor Act (RLA) due to their purported relation to collective bargaining agreements regarding employee passes. Plaintiff cross-moved for remand to state court, contending her claims were independent state law torts not preempted by federal labor law. The court, citing recent Supreme Court precedent in Hawaiian Airlines v. Norris, determined that the plaintiff's claims did not require interpretation of a collective bargaining agreement and thus were not preempted by the RLA. Therefore, the court concluded that the claims were purely factual questions suitable for a state court jury.

PreemptionRailway Labor ActState Law ClaimsTort ClaimsSubject Matter JurisdictionRemandDefamationFalse ImprisonmentEmotional DistressCollective Bargaining Agreement
References
12
Case No. ADJ9385010
Regular
Oct 04, 2018

JULIO LARA vs. TONY'S MARKET, STATE COMPENSATION INSURANCE FUND

This case involved a dispute over whether the Airline Deregulation Act preempts state common law regarding air ambulance fees under Labor Code section 4600(a). The applicant's air ambulance carrier, Reach, argued that federal law preempted state regulation of its rates. However, before the Appeals Board could issue a decision after reconsideration, the parties reached a settlement agreement. Consequently, Reach withdrew its petition, and the Board vacated its prior order granting reconsideration and dismissed the petition. The matter was returned to the trial level for approval of the settlement.

Airline Deregulation ActADA preemptionair ambulance feesreasonable expense standardLabor Code section 4600(a)common law reasonablenessfederal court decisionsseverability principlessettlement agreementpetition dismissal
References
1
Case No. MISSING
Regular Panel Decision
Sep 21, 2006

People v. Caridi

The defendant appealed a conviction for offering a false instrument for filing in the second degree, stemming from his false representation that workers on a HUD-funded project were paid the prevailing wage required by the federal Davis-Bacon Act. The defendant argued that state prosecution was preempted by federal law. The court disagreed, holding that the criminal proceeding was a valid exercise of the State’s police power with only a peripheral relationship to the Davis-Bacon Act, and there was no manifest Congressional intent to preempt state jurisdiction. Furthermore, the court found no conflict between state and federal law, as compliance with both was possible and state prosecution did not obstruct federal objectives.

False Instrument FilingDavis-Bacon ActFederal PreemptionState Police PowerSupremacy ClauseCriminal ProsecutionPrevailing WageHUD Funded ProjectConstruction ProjectConcurring Opinion
References
6
Case No. MISSING
Regular Panel Decision

Sheehan v. United States Postal Service

The plaintiff, a former letter carrier, sued the Union (Branch 81 and Branch 358) and Michael Hoag (Branch 81 president) for breach of duty of fair representation, fraudulent misrepresentation, wrongful discharge, and conspiracy after her termination from USPS. She alleged that Hoag falsely claimed to have filed an appeal for her termination grievance. The Court found the federal breach of duty of fair representation claim to be time-barred. It further ruled that the state law claims for wrongful discharge and conspiracy were preempted by federal labor law. The fraudulent misrepresentation claim was also deemed preempted by the NLRA. Consequently, the defendants' motion for summary judgment was granted, and the complaint was dismissed.

Breach of Duty of Fair RepresentationFraudulent MisrepresentationWrongful DischargeConspiracy (Labor Law)Statute of LimitationsSummary JudgmentFederal PreemptionLabor Management Relations ActNational Labor Relations ActCollective Bargaining Agreement
References
46
Case No. MISSING
Regular Panel Decision

Hoesten v. Best

Plaintiff Raymond J. Hoesten, a former stage manager, sued Constance Best, an AFTRA executive assistant, and AFTRA for defamation and tortious interference after his termination by ABC. Hoesten alleged Best's statements about his workplace conduct led to his dismissal. The court addressed whether some claims were time-barred, if federal labor law preempted state claims, and if actual or common-law malice was proven. The appellate court ruled that claims prior to July 1998 were time-barred, federal law partially preempted state defamation claims, and Hoesten failed to demonstrate malice. Ultimately, the court dismissed the complaint against both Best and AFTRA.

DefamationTortious InterferenceFederal Labor Law PreemptionActual MaliceQualified PrivilegeStatute of LimitationsSingle Publication RuleUnion LiabilityCollective Bargaining AgreementWorkplace Misconduct
References
42
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