Tenalp Construction Corp. v. Roberts
This case addresses whether the New York State Commissioner of Labor can mandate a public works contractor to pay prevailing wages to an employee who performs both supervisory and nonsupervisory tasks under Labor Law § 220. Petitioner Tenalp Construction Corp. challenged a prior determination by the Commissioner that it had willfully underpaid Steven Sauter, a superintendent/carpenter, for his carpentry duties on a public school construction project. The court affirmed the Commissioner's finding, emphasizing that an employee's job title does not override the nature of the work performed. It held that if the work is predominantly physical and falls under the statute's protection, the prevailing wage applies, regardless of additional supervisory roles. The court underscored the necessity for a liberal interpretation of Labor Law § 220 to fulfill its protective intent for workers.