Besante Fitzgerald Grant, Individually and on Behalf of All Others Similarly Situated, Appellant, v Global Aircraft Dispatch, Inc., Respondent., 223 A.D.3d 712

Summary

HOLDINGS: [1]-Labor Law § 198 did not expressly provide a private right of action to recover liquidated damages, prejudgment interest, and attorneys' fees where a manual worker is paid biweekly instead of weekly in violation of Labor Law § 191(1)(a); [2]-A private right of action cannot be implied for a violation of Labor Law § 191(1)(a) frequency of payment requirements, since the statute already provides enforcement mechanisms.