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Case Name New York v. United States Department of Labor PB-NY-0035
Docket / Court 1:20-cv-03020 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Public Benefits / Government Services
Special Collection COVID-19 (novel coronavirus)
Case Summary
COVID-19 Summary: On April 14, 2020, the State of New York filed this lawsuit in the U.S. District Court for the Southern District of New York to challenge Department of Labor regulations interpreting the Families First Coronavirus Response Act. Seeking declaratory and injunctive relief, the state ... read more >
COVID-19 Summary: On April 14, 2020, the State of New York filed this lawsuit in the U.S. District Court for the Southern District of New York to challenge Department of Labor regulations interpreting the Families First Coronavirus Response Act. Seeking declaratory and injunctive relief, the state alleged that the rule conflicted with the plain language and purpose of the statute by creating broad, unauthorized benefits exclusions and imposed new restrictions and burdens on employees. On August 3, the court denied the defendant's motion to dismiss and struck down four provisions of the FFRCA; the case closed shortly thereafter.


On April 14, 2020, the State of New York filed this lawsuit in the U.S. District Court for the Southern District of New York. The state sued the U.S. Department of Labor and the Secretary of Labor under § 702 and § 706 of the Administration Procedure Act. It sought declaratory and injunctive relief. Specifically, the state alleged that the U.S. Department of Labor’s regulations unlawfully narrowed workers’ eligibility for emergency family and paid sick leave guaranteed by the Families First Coronavirus Response Act (FFRCA), thus undermining the Act’s public health and economic security purposes.

The FFCRA reimbursed businesses that provided emergency family leave and paid sick leave for employees unable to work because of the coronavirus pandemic. On April 1, 2020, the Department of Labor released a final rule to implement these components of the Act that included broad exclusions and new restrictions. The state alleged that the Final Rule conflicted with the plain language and purpose of the statute Congress enacted. Namely, it claimed that the Rule limited employee eligibility to those circumstances where the employer determined in its sole discretion that the employer has work for the employee. The Rule also selected a broader definition of “health care provider” that would allow for more exemptions from the paid leave requirements and required employees to provide their employer with extensive documentation in order to obtain paid leave.

On April 14, 2020, the state filed a motion for summary judgment, arguing that the court should vacate the challenged restrictions. The case was assigned to Judge Paul Oetken.

On April 28, the defendant filed a motion to dismiss for lack of jurisdiction and a cross motion for summary judgment. They argued that New York State lacked standing, that the Department of Labor is entitled to Chevron Deference, and that the rule's requirements are a proper exercise of their rulemaking authority.

The court denied the defendant's motion to dismiss and granted in part and denied in part the cross-motions for summary judgment on August 3, holding that the decision to implement the four limitations under the FFRCA's regulations set by the Department of Labor exceeded its authority. 2020 WL 4462260. Specifically, the court struck down the definition of "health care provider," and the provisions that banned intermittent leave based on qualifying conditions that implicated an employee’s risk of COVID-19 transmission, that required employer consent for intermittent leave, and that required employees to submit documents to their employer prior to taking leave.

The court entered judgment on August 25 according to the August 3 opinion and order and closed the case.

Lily Sawyer-Kaplan - 07/06/2020
Averyn Lee - 09/14/2020
Chandler Hart-McGonigle - 11/30/2020


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Issues and Causes of Action
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Issues
Benefit Source
Families First Coronavirus Response Act (FFRCA)
Defendant-type
Jurisdiction-wide
General
Government Services (specify)
Public assistance grants
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Plaintiff Type
State Plaintiff
Causes of Action Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Defendant(s) Department of Labor
Secretary of Labor
Plaintiff Description State of New York
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Filed 04/14/2020
Case Closing Year 2020
Case Ongoing No
Additional Resources
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  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
Court Docket(s)
S.D.N.Y.
08/25/2020
1:20-cv-03020
PB-NY-0035-9000.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
General Documents
S.D.N.Y.
04/14/2020
Complaint for Declaratory na Injunctive Relief [ECF# 1]
PB-NY-0035-0001.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
04/14/2020
Memorandum of Law in Support of Plaintiff's Motion for Summary Judgment [ECF# 4]
PB-NY-0035-0002.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
04/28/2020
Notice of Defendants' Motion to Dismiss and Cross-Motion for Summary Judgment [ECF# 24]
PB-NY-0035-0003.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
04/28/2020
Memorandum of Law in Support of Defendants' Motion to Dismiss and Cross-Motion for Summary Judgment and in Opposition to Plaintiff's Motion for Summary Judgment [ECF# 25]
PB-NY-0035-0004.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
05/05/2020
Declaration of Matthew Colangelo [ECF# 26, 26-1, 26-2, 26-3, 26-4]
PB-NY-0035-0005.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
05/05/2020
Plaintiff's Memorandum of Law in Opposition to Defendants' Motion to Dismiss and Cross-Motion for Summary Judgment, and Reply in Support of Plaintiff's Motion for Summary Judgment [ECF# 27]
PB-NY-0035-0006.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
05/09/2020
Reply Memorandum of Law in Further Support of Defendant's Motion to Dismiss and Cross-Motion for Summary Judgment [ECF# 30]
PB-NY-0035-0007.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
08/03/2020
Opinion and Order [ECF# 37] (2020 WL 4462260)
PB-NY-0035-0008.pdf | WESTLAW | Detail
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Oetken, James Paul (S.D.N.Y.) show/hide docs
PB-NY-0035-0008 | PB-NY-0035-9000
Plaintiff's Lawyers Colangelo, Matthew (New York) show/hide docs
PB-NY-0035-0001 | PB-NY-0035-0002 | PB-NY-0035-0005 | PB-NY-0035-0006 | PB-NY-0035-9000
Haren, Eric R. (New York) show/hide docs
PB-NY-0035-0001 | PB-NY-0035-0002
James, Letitia (New York) show/hide docs
PB-NY-0035-0001 | PB-NY-0035-0002 | PB-NY-0035-0006
Kaye, Fiona Jeannette (New York) show/hide docs
PB-NY-0035-0001 | PB-NY-0035-0002 | PB-NY-0035-9000
Nogueira, Daniela (New York) show/hide docs
PB-NY-0035-0001 | PB-NY-0035-0002 | PB-NY-0035-9000
Defendant's Lawyers Berman, Geoffrey S. (New York) show/hide docs
PB-NY-0035-0003 | PB-NY-0035-0004 | PB-NY-0035-0007
Cha-Kim, Stephen Seungkun (New York) show/hide docs
PB-NY-0035-0003 | PB-NY-0035-0004 | PB-NY-0035-0007 | PB-NY-0035-9000
Jude, Jennifer Ann (New York) show/hide docs
PB-NY-0035-0003 | PB-NY-0035-0004 | PB-NY-0035-0007 | PB-NY-0035-9000
Other Lawyers Belovin, Allyson L. (New York) show/hide docs
PB-NY-0035-9000

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