Summary of May 2025’s Labor Law Cases in New York
Welcome to our roundup of New York labor law, employment and workplace rights cases from May 2025. Below is a summary of a notable employment law decision and some other relevant legislative developments from May 2025 in New York.
William Mattar, P.C. v. Riley — Appellate Division, Fourth Department (192 CA 24-00464)
Date decided: May 2, 2025
Summary: An attorney employed by William Mattar, P.C. was contractually entitled to a non-discretionary bonus based on her performance exceeding certain thresholds. However, her employment was terminated just before the firm deposited and cleared the fees that triggered the bonus, and the firm withheld payment citing the “continued employment” requirement. The employee challenged the withholding under New York Labor Law § 193(1) and the definition of wages inclusive of non-discretionary bonuses
Ruling: The Fourth Department held the withholding violated NYLL § 193(1) and public policy. It deemed any “bonus eligibility” clause conditioning payment on continued employment at payout time void and unenforceable.
Implications:
- Employers cannot lawfully withhold earned, non-discretionary bonuses by imposing a termination date condition.
- Such bonus payment provisions are void as against public policy.
- Businesses with bonus structures should ensure terms do not improperly condition vested bonus entitlements on continued employment.
Other Relevant Legislative Developments in New York in May 2025
Although not judicial decisions, two significant legislative developments occurred in May:
On May 9, 2025, Governor Hochul signed amendments to NY Labor Law §§ 191 and 198 (Part U, Chapter 56 of the Laws of 2025), significantly limiting liquidated damages in “frequency of pay” cases—capping first violations to interest-only damages and preserving full liquidated damages only for repeat violators. These changes apply immediately to pending and future actions.
Conclusion: Looking back on New York Labor Cases in May 2025
May 2025 brought a key appellate ruling affirming that non‑discretionary bonuses earned before termination cannot be withheld by employers, alongside landmark legislative reform limiting wage‑frequency damages. These developments underscore the importance for employers to audit their bonus policies and wage practices under New York labor law.
If you have questions about structured bonus plans or how new legislative limits on pay frequency liability could affect your business, HKM is here to help. Contact our labor law team to align policies with current New York workplace rights standards.
