Recent decisions
Real decisions applying freelancer protection laws, newest first by the date the decision was issued. Each summary states the stage the case was at, because surviving a motion to dismiss is not the same as winning. City enforcement settlements are labelled separately — they are negotiated agreements, not court rulings.
38 of 38 shown
- RetaliationNew York City and New York StateCourt decision
Petty v. Maison Hospitality Furnishings et al.
U.S. District Court, Southern District of New York · September 1, 2026 · SDNY 1:25-cv-06342, Document 26
A remote freelance marketing contractor sued an out-of-state hiring party in federal court in Manhattan, alleging unpaid compensation and retaliation under both the State and City freelance laws.
What was decided: Motion to dismiss granted in part and denied in part. The State payment claim, City payment claim, alternative contract claim, State/City retaliation claim and two further counts all survived; the defamation count was dismissed without prejudice for lack of personal jurisdiction. Pleading stage — no liability finding, no damages.
Significance: One of the few decisions handling City and State freelance claims together, and treating remote work performed for a New York engagement as sufficiently connected to New York at the pleading stage.
- Written contractsNew York CityCourt decision
Dunphy v Giuliani
Supreme Court, New York County · March 30, 2026 · Index No. 650033/2023
A written-contract claim under the City law was attacked as filed too late among several claims in the lawsuit.
What was decided: The court rejected the timeliness argument as to the written-contract claim, applying COVID-era tolling.
Significance: Deadlines can be affected by tolling. The date on the calendar is not always the whole answer.
- Who is protectedNew York CityCourt decision
Fischer v Frisch
Supreme Court, New York County · March 24, 2026 · Index No. 653070/2025
A real-estate broker sought unpaid commissions under the City freelance law.
What was decided: The freelance claim was dismissed under the court's reading of the sales-representative exclusion. Other contract issues were addressed separately.
Significance: The sales-representative exclusion is written into the definition of freelance worker, and it has real consequences for commission-based work.
- City enforcementNew York CityCity enforcement settlement
DCWP / Splashlight
NYC Department of Consumer and Worker Protection · February 24, 2026 (announcement) · Not yet obtained
The City announced a settlement covering unpaid and late-paid freelance work involving 350 freelancers.
What was decided: $528,817 announced in restitution and civil penalties. This is one enforcement matter, not 350 cases. The signed agreement and completion of payment have not been verified here.
Significance: City enforcement is a separate route from your own lawsuit, and a settlement is not a court ruling.
- Regulation and preemptionNew York StateCourt decision
Maplebear Inc. (d/b/a Instacart) v. City of New York et al.
U.S. District Court, Southern District of New York · January 22, 2026 · SDNY 1:25-cv-09979, Document 40
Instacart argued that the New York State Freelance Isn't Free Act preempts New York City's grocery-delivery local laws and asked the court to block the City rules. This is a company challenging regulation, not a freelancer seeking pay.
What was decided: Preliminary injunction denied. The court rejected the field- and conflict-preemption arguments, found no irreparable harm, and found the equities and public interest did not favor relief. Preliminary-relief standard only, not a final merits judgment.
Significance: It shows the State freelance law being litigated as a limit on city regulation, which is a different question from an individual's right to be paid.
- Remedies and deadlinesNew York CityCourt decision
St. Clement v Fuchs
Supreme Court, New York County · January 22, 2026 · Index No. 154359/2025
A second lawsuit raised seven freelance-law causes of action after an earlier related case between the same parties.
What was decided: The action was dismissed on preclusion and limitations grounds; sanctions denied.
Significance: Bringing the same dispute twice, or bringing it late, can end a claim before its merits are ever reached.
- Remedies and deadlinesNew York CityCourt decision
Marko Constr. LLC v Berman
Supreme Court, New York County · January 21, 2026 · Index No. 654129/2023
A construction-services lawsuit included a City freelance claim that the defendant argued was untimely.
What was decided: The freelance claim was dismissed as untimely under the two-year period the parties agreed applied; other claims continued.
Significance: The period applied here reflected the parties' own position in that case. Deadlines under § 20-933 differ by claim type and should not be generalized.
- Getting paidNew York CityCourt decision
Riad LLC v Northco Mgt. Inc.
Supreme Court, New York County · December 19, 2025 · Index No. 654717/2023
A single-member consulting business alleged that a conditional bonus was paid late.
What was decided: Dismissal denied because whether the payment was timely was unresolved; other claims were partly dismissed.
Significance: Late payment, not only non-payment, can support a claim.
- Getting paidNew York CityCourt decision
Montfort v Leslie J. Garfield & Co., Inc.
Supreme Court, New York County · November 7, 2025 · Index No. 650998/2025
A real-estate commission dispute asserted City freelance payment protection over a disputed listing.
What was decided: The freelance claim was dismissed because no enforceable agreement covered the listing; sanctions denied.
Significance: Without an enforceable agreement establishing what was owed, a payment claim can fail at the threshold.
- Written contractsNew York City and New York StateCourt decision
Gordon v. Equitas Capital Group LLC
U.S. District Court, Southern District of New York · September 29, 2025 · SDNY 1:24-cv-06789, Doc. 38
City and State freelance claims were brought in federal court without a sufficiently pleaded enforceable agreement.
What was decided: Both claims dismissed without prejudice, with leave to amend. No damages awarded.
Significance: Pleading what the agreement actually was, and how it was formed, matters before anything else is reached.
- Who is the hiring partyNew York CityCourt decision
Ortiz et al. v. Consolidated Edison Company of New York, Inc. et al.
U.S. District Court, Southern District of New York · September 24, 2025 · SDNY 1:22-cv-08957, Document 294
Workers engaged indirectly through subcontractors brought alternative City freelance claims against the company at the top of the chain.
What was decided: Motion to dismiss denied; hiring-party status was sufficiently alleged despite the indirect engagement. Pleading stage — not a liability finding.
Significance: Indirect engagement through a subcontractor did not by itself defeat the claim at the pleading stage.
- Who is the hiring partyNew York CityCourt decision
SF Entities, Inc. v. Gamburg and Cova Laboratories, LLC
U.S. District Court, Eastern District of New York · September 11, 2025 · 1:23-cv-04881-AMD-LKE, Doc. 51
A federal case over City freelance claims turned on which defendant hired the worker and whether the corporate form could be looked past.
What was decided: The plaintiff's partial summary-judgment motion was denied and claims against the individual were dismissed because he was not the hiring party and veil piercing was not established. Disputes over freelance-worker status, New York City connection and compensation remained for trial.
Significance: Suing the person behind the company does not work automatically — the hiring party is a specific statutory role.
- Remedies and deadlinesNew York CityCourt decision
Whitfield v Law Enforcement Empls. Benevolent Assn. (LEEBA)
Supreme Court, New York County · August 4, 2025 · Index No. 656521/2022
A claimant who built a website and separately provided paralegal services sued for unpaid work and the absence of a written contract.
What was decided: Judgment granted to the claimant on the website payment and written-contract claims; the paralegal-services claim was severed and continued.
Significance: An example of a freelancer actually winning part of a case on summary judgment.
- Written contractsNew York CityCourt decision
Tam-Zegarra v Pleroma Mgmt, LLC
Supreme Court, New York County · June 26, 2025 · Index No. 652019/2025
A consulting-agreement payment claim was met with the argument that the written contract was defective.
What was decided: The freelance claim survived dismissal.
Significance: An imperfect written contract did not eliminate statutory protection.
- Who is protectedNew York CityCourt decision
Balestra v Wonderfield, LLC.
Supreme Court, Kings County · May 23, 2025 · Index No. 527517/2024
A freelance producer's City freelance claim was tested against the requirement that the organization consist of no more than one person.
What was decided: The freelance cause was dismissed because the plaintiff alleged operating collectively with two other individuals; other parts of the lawsuit continued.
Significance: How you describe your own working arrangement can decide coverage.
- City enforcementNew York CityCity enforcement settlement
DCWP v. BuzzFeed Media Enterprises, Inc.
NYC Department of Consumer and Worker Protection · May 8, 2025 (last signature; announced June 5) · 2024-03729-ENF; 40614-2025-ADJC
A city investigation into freelance payment practices was resolved by consent order without a trial.
What was decided: $45,424.23 in statutory relief for 16 freelancers plus $4,575.77 in civil penalties, with additional-claim provisions. Agreed amounts, not verified payments.
Significance: Shows what agency enforcement produces, and that these are negotiated outcomes rather than judicial findings.
- Who is protectedNew York CityCourt decision
Joseph Chen, Inc. v Romona Keveza Collection LLC
Appellate Division, First Department · April 24, 2025 · Index No. 153413/20|Appeal No. 4191|Case No. 2024-03863|
An appellate court reviewed whether freelancers who used assistants and were represented by an agent qualified for the City law's protection.
What was decided: Summary judgment on liability granted to the freelancers against Romona Keveza Collection; the remainder affirmed. Liability only — damages were not fixed here.
Significance: An appellate decision, which carries more weight than a trial-level order, on the coverage of a single-person business that uses assistants.
- Who is the hiring partyNew York CityCourt decision
Rocha v Tea at Five on Broadway LLC
Supreme Court, New York County · January 23, 2025 · Index No. 157978/2019
A freelance claim pleaded as an alternative to employee claims was pressed against several different defendants.
What was decided: Dismissed as to one individual defendant; the broader dismissal sought by the other defendants was largely denied.
Significance: Results can differ defendant by defendant in the same case, so a single win-or-lose label is misleading.
- Written contractsNew York CityCourt decision
Provenzano v Orwel
Civil Court of the City of New York, New York County · December 10, 2024 · Index No. SC-000651-21/NY
A small-claims trial in New York City Civil Court addressed payment and written-contract relief where the arrangement was oral.
What was decided: Freelance damages denied for failure to establish an enforceable contract and the required written-contract request; recovery was awarded instead on unjust enrichment.
Significance: Even where a court finds the work was worth paying for, the freelance-law remedy can still fail without the right proof.
- Written contractsNew York CityCourt decision
McNamara v Negative, Inc.
Supreme Court, New York County · November 18, 2024 · Index No. 651709/2024
A freelancer with recurring work alleged unpaid and late-paid invoices and no written agreements.
What was decided: Written-contract claims before April 3, 2022 dismissed as untimely; the rest survived. Invoices did not satisfy the prospective written-contract requirement.
Significance: Invoicing after the fact is not the same as agreeing terms in writing in advance.
- Arbitration and procedureNew York CityCourt decision
Snazzi Reporting, Inc. v Veritext, LLC
Appellate Division, First Department · October 31, 2024 · Index No. 650680/22 Appeal No. 2957 Case No. 2023-04022
A court-reporting business's freelance claims were pushed out of court and into arbitration under the parties' agreement.
What was decided: The appellate court required arbitration under the agreement and the Federal Arbitration Act, expressly not reaching the merits of the freelance claims.
Significance: An arbitration clause in your contract can decide where — not whether — your claim is heard.
- Timing and effective dateNew York CityCourt decision
Er v Genie Quest LLC
Supreme Court, New York County · September 4, 2024 · Index No. 652925/2019
After a bench trial, the plaintiff sought doubled damages under the City freelance law on a March 2017 agreement.
What was decided: Freelance relief denied because the agreement predated the law's effective date; $18,333.32 in contract damages awarded against one defendant.
Significance: The City law took effect May 15, 2017. Agreements made before then have been held outside it.
- Who is the hiring partyNew York CityCourt decision
Frisch v. Likeopedia, LLC
U.S. District Court, Southern District of New York · August 26, 2024 · SDNY 23-cv-3904 (VM), Doc. 34
After the state case was discontinued, the consultant's freelance claim continued in federal court against the company and its principal.
What was decided: The claim survived against the company but was dismissed against the individual because he was not the hiring party. No damages awarded.
Significance: The same dispute can move courts; the hiring-party question follows it.
- Written contractsNew York CityCourt decision
Hartman v Pilata Inc.
Supreme Court, New York County · December 1, 2023 · Index No. 650961/2022
On reargument, the court revisited its own earlier reading of the written-contract requirement.
What was decided: The prior interpretation was corrected and two causes of action were restored.
Significance: Trial courts have reached different readings of the written-contract rules, and have changed their minds.
- Who is protectedNew York CityCourt decision
MJ Lilly Assoc., LLC v Ovis Creative, LLC
Appellate Division, Second Department · November 15, 2023 · 2021-09468
A hiring party tried to defeat freelance-worker status at the outset using emails and website printouts.
What was decided: The appellate court affirmed the denial of dismissal; the documents did not conclusively defeat freelance-worker status.
Significance: Documents have to be conclusive to end a case early. Arguable inferences are not enough.
- City enforcementNew York CityCity enforcement settlement
City of New York v. L’Officiel USA Inc.
NYC Department of Consumer and Worker Protection · July 11, 2023 (effective date) · New York County 453762/2021
The City's pattern-or-practice lawsuit against a publisher was resolved by a published agreement.
What was decided: The City release reports more than $275,000 for 41 identified freelancers. The settlement is not an admission of liability and payment completion has not been verified.
Significance: Pattern-or-practice enforcement targets repeated conduct across many freelancers at once.
- Remedies and deadlinesNew York CityCourt decision
Tan v Breathing.AI LLC
Supreme Court, New York County · June 20, 2023 · Index No. 650043/2023
A consultant alleged no written agreement and unpaid compensation across a long working relationship.
What was decided: The written-contract claim was partly time-barred; remaining freelance claims survived, and quasi-contract claims were dismissed as duplicative.
Significance: Long relationships get sliced by dates: some periods can be too old while later ones proceed.
- Where the law appliesNew York CityCourt decision
Frisch v Likeopedia, LLC
Supreme Court, New York County · May 8, 2023 · Index No. 651876/2021
A consultant's City freelance payment claim was challenged on the strength of its New York City connection.
What was decided: Dismissal denied; alleged New York City residence and work were sufficient at the pleading stage.
Significance: Compare with Turner: how the New York City connection is pleaded and proved makes the difference.
- Timing and effective dateNew York CityCourt decision
Wark v Cameron Engg. & Assoc., L.L.P.
Supreme Court, New York County · March 16, 2023 · Index No. 651231/2020
An engineer sought compensation across several projects governed by contracts from different years.
What was decided: The freelance law applied to the 2018 contract but not the 2016 contracts; partial summary judgment and a money judgment were ordered, with fees reserved.
Significance: Within one relationship, some contracts can be covered and others not.
- Who is protectedNew York CityCourt decision
Varn v. Orchestrade, Inc.
U.S. District Court, Eastern District of New York · March 26, 2022 · EDNY 19-cv-2875 (MKB); removed from Kings 509102/2019
The same dispute produced two very different results at two stages: a 2020 ruling let the freelance claim past dismissal, and this 2022 decision resolved it on a fuller record.
What was decided: Summary judgment granted to the defendants on the underpayment and retaliation claims under the sales-representative exclusion. Contract issues remained.
Significance: Surviving a motion to dismiss is not winning. The same claim can fail later once evidence is in.
- Who is protectedNew York CityCourt decision
Paolitto v Ladders, Inc.
Supreme Court, New York County · February 28, 2022 · Index No. 655289/2020
The contracting entity had two members, and the hiring party argued that put it outside the law.
What was decided: Complaint dismissed; permission to add the LLC for a contract claim did not revive the freelance claims.
Significance: The definition covers an organization of no more than one natural person. Two owners changed the outcome here.
- Remedies and deadlinesNew York CityCourt decision
StClair v Sansal
Civil Court of the City of New York, New York County · September 14, 2021 · SCNY-16201/2020-1
A consultant tried an unpaid-compensation case under the City freelance law in New York City Civil Court.
What was decided: Judgment awarded against the hiring company with doubled damages; claims against the individual personally were dismissed.
Significance: A concrete example of doubled damages actually being awarded, and of the limits on individual liability.
- Who is the hiring partyNew York CityCourt decision
Monzano-Moreno v. Libqual Fence Co., Inc.
U.S. District Court, Eastern District of New York · February 5, 2021 · EDNY 18-cv-0161 (MKB)(AKT); 2021 WL 730663
A magistrate judge's report and recommendation addressed alternative freelance claims against defendants who were not the entity that hired the workers.
What was decided: Recommended summary judgment for the moving defendants: even assuming freelance-worker status, a different company was the hiring party. Later opinions cite a February 23, 2021 adoption; this project has not obtained the adoption order itself.
Significance: A report and recommendation is a recommendation to a district judge, not by itself a final ruling.
- Timing and effective dateNew York CityCourt decision
Lau v Tykoon Brand Holdings LLC
Supreme Court, New York County · September 4, 2020 · 651473/2020
A creative-services claim rested on an alleged 2016 agreement.
What was decided: The freelance claim was dismissed because the agreement predated the effective date; other causes were addressed separately.
Significance: Another decision applying the May 15, 2017 effective date.
- Where the law appliesNew York CityCourt decision
Turner v Sheppard Grain Enters., LLC
Supreme Court, New York County · June 23, 2020 · 652509/2019
A consultant who worked mainly outside New York City sought fees under the City law.
What was decided: The freelance causes were dismissed under the court's New York City impact analysis.
Significance: The City law is a city law. Where the work happened and who it affected can decide the case.
- Who is the hiring partyNew York CityCourt decision
Iams v 10X Mgt. LLC
Supreme Court, New York County · May 29, 2020 · 656266/2019
A freelancer sued both the company that engaged him and his own management agent.
What was decided: The freelance claim was dismissed against both defendants, with leave to amend against one; the management company was the freelancer's agent, not the hiring party. No monetary award.
Significance: Your agent is generally not the hiring party. This project has a source link only for this decision; no copy is saved here.
- Who is the hiring partyNew York CityCourt decision
Van Den Berg v Clinton Hall Holdings, LLC
Supreme Court, New York County · July 8, 2019 · 653156/2018
A mural artist sought to rely on the hiring party's failure to respond to a city administrative complaint.
What was decided: Both sides were denied summary judgment; who the hiring party was remained disputed and the supporting affirmation was defective.
Significance: A non-response presumption helps, but it does not replace evidence of who hired you.
- RetaliationNew York CityCourt decision
Sandles v Magna Legal Servs., LLC
Civil Court of the City of New York, New York County · December 18, 2018 · CV-013330-18
A freelance court reporter brought a retaliation claim after filing an administrative complaint.
What was decided: The administrative complaint did not bar the lawsuit, but the retaliation claim failed because the conduct relied on was not the exercise of a protected right.
Significance: Retaliation claims depend on which activity the statute actually protects.
These are curated summaries of selected decisions, not a complete list of every freelance-law ruling, and later appeals or docket activity have not been comprehensively checked. The full record library shows every record kept here and how it was gathered.