Macks USA, Inc v. United States Department of Labor

CourtDistrict Court, S.D. New York
DecidedNovember 8, 2024
Docket1:23-cv-07476
StatusUnknown

This text of Macks USA, Inc v. United States Department of Labor (Macks USA, Inc v. United States Department of Labor) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Macks USA, Inc v. United States Department of Labor, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ──────────────────────────────────── MACKS USA, INC., ET AL.,

Plaintiffs, 23-cv-7476 (JGK)

- against - MEMORANDUM OPINION AND ORDER UNITED STATES DEPARTMENT OF LABOR, ET AL.,

Defendants. ──────────────────────────────────── JOHN G. KOELTL, District Judge:

The plaintiffs, Macks USA, Inc. (“Macks”) and Mujeeb Rahman, brought this action seeking judicial review of an Administrative Review Board (“ARB”) Decision and Order (the “ARB D&O”). In the ARB D&O, the ARB, a body authorized to issue final decisions for the Secretary of Labor, affirmed the Administrative Law Judge’s (“ALJ’s”) decision (the “ALJ D&O”) upholding the Department of Labor’s (“DOL’s”) initial determination letter (the “WHD Letter”) finding that the plaintiffs owed back wages to Shaukakt Jalal, a former Macks employee, and imposing a civil penalty on Macks and Rahman. The defendants filed a counterclaim seeking to affirm the ARB D&O. The defendants now move for summary judgment affirming the ARB D&O and dismissing the plaintiff’s complaint. For the following reasons, the defendants’ motion for summary judgment is granted. I. In deciding a motion for summary judgment under Rule 56, courts “grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.”1 Fed. R. Civ. P. 56(a);

see Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986); Gallo v. Prudential Residential Servs. L.P., 22 F.3d 1219, 1223 (2d Cir. 1994). However, where “a party seeks review of agency action under the APA, the district judge sits as an appellate tribunal, and the entire case on review is a question of law.” Ass'n of Proprietary Colls. v. Duncan, 107 F. Supp. 3d 332, 344 (S.D.N.Y. 2015). Accordingly, the usual summary judgment standard under Rule 56 does not apply because the Court need only “address legal questions” to decide “whether the agency acted arbitrarily, capriciously or in some other way that violates 5 U.S.C. § 706.” Id. Nonetheless, summary judgment is appropriate in APA cases because the questions on review are

purely legal and are “amenable to summary disposition.” Id. Under the APA, courts review issues of law de novo, without any deference to an agency’s interpretations of the statutes that the agency is charged with administering. 5 U.S.C. § 706 (“[T]he reviewing court shall decide all relevant questions of

1 Unless otherwise noted, this Memorandum Opinion and Order omits all internal alterations, citations, footnotes, and quotation marks in quoted text. law . . . .”); Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244, 2261–63, 2273 (2024) (overruling Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (1984)). Pursuant to section 706(2), courts must “hold unlawful and set aside agency action[s]” that are “arbitrary, capricious, an abuse of

discretion, or otherwise not in accordance with law,” “contrary to constitutional right, power, privilege, or immunity,” or “unsupported by substantial evidence.” 5 U.S.C. § 706(2)(A)–(B), (E). “[A] district court’s review under the arbitrary and capricious standard is limited to the administrative record.” Miller v. United Welfare Fund, 72 F.3d 1066, 1071 (2d Cir. 1995). II. A. This case concerns the H-1B visa provisions of the Immigration and Nationality Act (the “INA”), 8 U.S.C. § 1101(a)(15)(H)(i)(b) & § 1182(n), as amended by the American

Competitiveness and Workforce Improvement Act (the “ACWIA”) of 1998, Pub. L. No. 105-277, 112 Stat. 2681, 2681-641 (1998), the H-1B Visa Reform Act of 2004, Pub. L. No. 108-447, 118 Stat. 2809 (2004), and the DOL’s implementing regulations at 20 C.F.R. Part 655, subpts. H & I. Descriptions of the relevant laws, regulations, and agencies follow. 1. The H-1B visa program, enacted pursuant to the INA, allows employers to bring temporary workers to the United States under certain conditions to perform “specialty occupation[s].” See 8 U.S.C. § 1101(a)(15)(H)(i)(b). Congress has imposed standards on

employers hiring H-1B workers. 8 U.S.C. § 1182(n). As relevant in this case, the H-1B program requires employers to pay H-1B workers a required wage rate: the higher of the actual wage or the prevailing wage level for the occupational classification in the area of employment. See § 1182(n)(1)(A). Congress delegated enforcement of these standards to the DOL. § 1182(n)(1)–(2). As a precursor step in the process of obtaining an H-1B visa through the United States Citizenship and Immigration Services (“USCIS”) and the Department of State, employers must submit a Labor Condition Application (“LCA”) to the DOL and receive DOL certification. DOL, Labor Condition Application, https://flag.dol.gov/programs/LCA (last visited Nov. 4, 2024).

When employers submit an LCA to the DOL, employers promise to pay the required wage rate and to provide certain working conditions. Id.; § 1182(n)(1)(A). An employer must pay an H-1B employee the prevailing wage listed on the employee’s LCA starting on the date the employee “‘enters into employment’ with the employer.” 20 C.F.R. § 655.731(c)(6). An H-1B employee “‘enter[s] into employment’ when he/she first makes him/herself available for work or otherwise comes under the control of the employer.” 20 C.F.R. § 655.731(c)(6)(i). The obligation to pay wages continues even if an H-1B employee is not actually performing work—namely, even if the employee is in “nonproductive status” (i.e., is “benched”)—

except during certain specified types of nonproductive periods. See 8 U.S.C. §§ 1182(n)(2)(C)(vii)(I), (IV); 20 C.F.R. § 655.731(c)(7). The employer’s obligation to pay the H-1B employee ends only once the approved period of the LCA expires, or if there has been a “bona fide” termination of the employment relationship prior to that time. See 20 C.F.R. § 655.731(c)(7)(ii).

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Macks USA, Inc v. United States Department of Labor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/macks-usa-inc-v-united-states-department-of-labor-nysd-2024.