LAWSUITS FOR LATE PAYMENT OF WAGES IN NEW YORK
Liquidated Damages Pursuant to Section 191 of the New York Labor Law



Written by Marc Rapaport

New York Requires Weekly Payment of Wages to Manual Workers.

Section 191(1)(a)(i) of the New York Labor Law (NYLL) requires weekly payment of wages to manual workers.  The NYLL defines manual workers broadly. NYLL section 190(4) defines a “manual worker” as “a mechanic, workingman, or laborer.” The New York Department of Labor has long interpreted the term to include “employees who spend more than 25 percent of their working time performing physical labor.” Rankine v. Levi Strauss & Co., No. 22-CV-03362-LTS, 2023 U.S. Dist. LEXIS 89064, 2023 WL 3582323, at * 6 (S.D.N.Y. May 22, 2023) (quoting N.Y. Dep’t of Labor Opinion Letter, No. RO-09-0066 (May 21, 2009)).

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