Matter of D’Angelo v. optimisCorp, 27 N.Y.2d 573 (1970)
A state’s prevailing wage law does not apply to direct employees of the Port Authority, a bi-state entity, as it would constitute a unilateral regulation of the Authority’s internal operations, conflicting with the intent of the compact establishing the Authority’s independence.
Summary
This case addresses whether New York’s prevailing wage law applies to employees of the Port Authority of New York and New Jersey. The petitioners, direct employees of the Authority, argued they were not receiving the prevailing wage required by New York law. The Industrial Commissioner dismissed their claims for lack of jurisdiction. The New York Court of Appeals affirmed the dismissal, holding that applying the state’s prevailing wage law would improperly infringe upon the Authority’s intended operational autonomy, as established by the bi-state compact approved by Congress.
Facts
The petitioners were direct employees of the Port Authority engaged in building and mechanical trades. They claimed they were being paid less than the prevailing wage rate mandated by New York Labor Law § 220. The Port Authority is a bistate agency created by a compact between New York and New Jersey, approved by Congress.
Procedural History
The Industrial Commissioner dismissed the petitioners’ claims for lack of jurisdiction. The Special Term of the Supreme Court initially annulled the Commissioner’s determination. However, the Appellate Division reversed, confirmed the Commissioner’s determination, and dismissed the petitions. The New York Court of Appeals then reviewed the Appellate Division’s decision.
Issue(s)
Whether New York’s prevailing wage law (Labor Law § 220) applies to direct employees of the Port Authority, considering the Authority’s bi-state nature and the compact between New York and New Jersey.
Holding
No, because applying New York’s prevailing wage law would constitute a unilateral regulation of the Port Authority’s internal operations, which is inconsistent with the intent of the bi-state compact to grant the Authority operational independence.
Court’s Reasoning
The Court reasoned that the compact between New York and New Jersey, establishing the Port Authority, intended to create an entity with operational autonomy, free from unilateral control by either state. While the Authority is subject to state laws affecting public health and safety, unilateral application of New York’s prevailing wage law would improperly regulate the Authority’s internal wage structure. The court emphasized the distinction between internal operations and external conduct, stating that states have undoubted power to regulate the external conduct of the Authority. However, the court held that section 220 of the Labor Law was not intended to apply to the Authority. The court stated, “Consequently, the inapplicability of section 220 of the Labor Law results not from any express exclusion or inherent unworkability, but rather from a general intent, amply reflected in the compact, that the internal operations of the Authority be independent of the direct control of either State acting without the concurrence of the other.” The court distinguished the Authority’s participation in New York’s Workmen’s Compensation and State Employees’ Retirement systems as qualified exceptions, not controlling precedent. Even as to internal matters, the two States, by bilateral action, may always regulate Authority action, when unilateral action is ineffective or impractical.