Celesq® Programs

Pay Frequency Litigation in New York

Program Number
Program Date
CLE Credits

Section 191(1)(a)(i) of the New York Labor Law requires employers to pay “manual workers” on a weekly basis. For decades, courts held that employees could not sue their employers to redress violations of this provision. In 2019, however, a New York appellate court held that the statute provides a private right of action, which triggered a tidal wave of class action litigation seeking liquidated damages for untimely wages. 

This program covers the legislative history, recent litigation trends, and unresolved issues concerning Section 191, among other topics involving pay frequency litigation in New York.

Available in States

  • California
  • Colorado
  • Florida
  • Georgia
  • New Jersey
  • New York
  • Texas Self Study

Program Categories

  • Complex Litigation
  • Employee Benefits & Compensation
  • Employment & Labor Law
  • Federal Courts
  • Florida Eligible
  • Litigation & Litigation Skills
  • Litigation and Appeals
  • Trial Skills


  • Areas of Professional Practice : 1 Credit