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.