Rochester Club v. New York State Labor Relations Board
The petitioner, an employer, was charged with unfair labor practices by the New York State Labor Relations Board. Despite a trial examiner's recommendation to dismiss the complaint, the Board found unfair labor practices and ordered the matter reopened for further hearings to determine employee reinstatement and back pay. The petitioner initiated an Article 78 proceeding to review this Board order, which the Board moved to dismiss as non-final. The court held that under New York Labor Law, the Board's order, granting no relief and requiring further evidence, is an interlocutory order not subject to immediate judicial review. The court distinguished this from federal practice, where similar orders may be considered final, due to differences in state and federal procedural acts. Consequently, the court dismissed the petition, ruling that a final order from the Board was still pending.