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Federal Judge Blocks New York’s Bid to Shift Private-Sector Labor Cases to State Board

The ruling finds New York’s SERA amendments preempted by federal law under Garmon, keeping NLRA disputes with the NLRB.

Overview

  • On Nov. 26, Judge Eric R. Komitee granted Amazon a preliminary injunction halting enforcement of SERA amendments that extended PERB jurisdiction to most private employers.
  • The court concluded the law is likely preempted by the NLRA under the Supreme Court’s Garmon doctrine and rejected New York’s argument for a “unique circumstances” exception tied to the NLRB’s quorum issues.
  • PERB is enjoined from applying the amendments to private-sector matters, while its existing authority over public and agricultural employers remains unchanged.
  • A separate NLRB lawsuit challenging New York’s measure continues, and an appeal to the Second Circuit is expected.
  • The decision channels new representation and unfair labor practice disputes back to the NLRB, affecting filings such as the Amazon Labor Union case.