Matter of Roosevelt Raceway, Inc. v. Monaghan, 24 N.Y.2d 465 (1969)
A statute or amendment is presumed to apply prospectively unless the language clearly indicates a contrary intention, especially when the statute creates new rights or obligations that could impair existing contractual agreements.
Summary
Roosevelt Raceway contracted with the State to perform electrical work, specifying two classes of workmen: electricians and electrician-apprentices. After the contract was executed, New York amended its Labor Law to require individual registration in an apprenticeship program for employees to be considered apprentices. The Industrial Commissioner argued that because the employees were not registered as apprentices, they were entitled to electrician wages from the amendment’s effective date. The court held that the amendments could not be applied retroactively to the existing contract because they created new obligations and rights and could impair the existing contractual obligations.
Facts
In November 1965, Roosevelt Raceway contracted with the State of New York for electrical work at the State armory in Manhattan. The contract and specifications defined two classes of workers: “electrician” and “electrician-apprentice-lst term.” When work began in February 1966, Roosevelt Raceway hired employees as apprentices, paying them less than electricians, but equal to or exceeding the prevailing rate established for apprentices. In September 1966, New York amended Labor Law § 220(3), requiring individual registration in an apprenticeship program for employees to be deemed apprentices. A further amendment in July 1967 stipulated that unregistered employees be paid wages corresponding to the work they performed.
Procedural History
The Industrial Commissioner, following the amendments to the Labor Law, held hearings and determined that because certain employees were not registered in an apprenticeship program as of September 1, 1966, they were entitled to wages as “mechanic electricians.” The Appellate Division partially agreed with the Industrial Commissioner’s determination but the case was appealed to the New York Court of Appeals.
Issue(s)
Whether amendments to Labor Law § 220(3), requiring apprenticeship program registration, apply retroactively to contracts executed before the amendments’ effective dates, where such application would create new obligations and rights and potentially impair existing contractual obligations.
Holding
No, because the amendments create new requirements that, if unmet, offer immediate recourse to employees, and applying them retroactively would impair existing contractual obligations. The case was remitted for further proceedings regarding the employees’ original claim that they were hired and performed work as electricians.
Court’s Reasoning
The Court of Appeals held that the amendments to the Labor Law should not be applied retroactively. The court reasoned that the postponement of the effective dates of the amendments indicated a legislative intent for prospective application. “[I]t is axiomatic that an amendment will have prospective application only, unless its language clearly indicates that a contrary interpretation is to be applied.” The court emphasized that the amendments did more than prescribe procedural requirements; they created new requirements that employers had to meet, providing employees with immediate recourse if these requirements were breached. This creation of new rights and obligations distinguished the case from situations involving mere procedural changes. The court also noted that retroactive application could raise constitutional concerns by imposing new conditions on existing contracts, potentially impairing their obligations. The court stated, quoting Longines-Wittnauer Watch Co. v. Barnes & Reineche, that “where the effect of the statute ‘is to create a right of action’ which did not previously exist, it is presumed that the statute was intended to have only prospective application.” While addressing the retroactivity issue, the Court noted that the employees had also claimed they performed the work of electricians. The Court was unable to determine the veracity of this claim, and remitted the case to the Appellate Division for a proper determination.