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Methodology and coverage

This library is a research collection of publicly located New York City Freelance Isn’t Free Act matters, assembled and reviewed by Lawson. Snapshot date: September 8, 2026. It is a record of what was found and preserved, with its gaps stated rather than smoothed over.

What the numbers mean

The collection holds 43 dispute and enforcement matters: 40 court-dispute groups and 3 city enforcement matters. Those matters are documented by 53 individual records (50 court records and 3 enforcement records).

Matter count and opinion count are different measures. A single dispute can produce several opinions and can carry more than one index or docket number; related actions are grouped by underlying dispute. 43 is not 43 dockets, not 43 full case files, and not every NYC Freelance Isn’t Free Act case in existence.

Reconciliation, step by step

  1. Initial opinion search returned 40 results: 38 retained opinions and 2 excluded as unrelated matches.
  2. Those 38 retained opinions represent 31 underlying case groups.
  3. Supplements added three further court matters: Iams v 10X Mgt. LLC, SF Entities v. Gamburg, and Ortiz v. Consolidated Edison — 34 court matters.
  4. Three city enforcement matters were added: BuzzFeed, L’Officiel and Splashlight — a 37-matter baseline.
  5. The citation-expansion pass added four new dispute groups — Gordon, Varn, Ward and Monzano-Moreno — and three additional history opinions that join existing groups (Clement into St. Clement, the federal Frisch opinion into Frisch, and Kenzo 30943(U) into Kenzo).
  6. On September 8, 2026 two decisions found by the daily decision watch were reviewed and approved into the library, adding two court-dispute groups: Petty v. Maison Hospitality Furnishings (S.D.N.Y., Sept. 1, 2026) and Maplebear Inc. (Instacart) v. City of New York (S.D.N.Y., Jan. 22, 2026). Maplebear is a regulatory preemption challenge, not an individual recovery claim, and is labeled that way on its page.
  7. Result: 40 court-dispute groups + 3 enforcement matters = 43 matters, held in 53 records. The total was computed from the records themselves and matches the expected reconciliation; no count was forced.

Sources used

  • The initial 40-result opinion search from the New York State Law Reporting Bureau, preserved in full including the excluded results.
  • Federal records (SF Entities v. Gamburg, from the official government PDF).
  • Additional state records (Iams v 10X Mgt. LLC).
  • Article-based additions (Ortiz v. Consolidated Edison; DCWP / Splashlight).
  • City enforcement records (DCWP v. BuzzFeed consent order; City of New York v. L’Officiel settlement).
  • Citation records from the September 6, 2026 citation-expansion pass (seven new opinion records).

Overlapping entries between these sources were deduplicated, and related dockets were grouped into a single dispute where the records show they belong to one dispute.

Inclusion and exclusion rules

A record is retained when it adjudicates or discusses a Freelance Isn’t Free Act claim, defense, remedy or forum issue — including dismissals and counterclaims — or when it is a procedural or later-history decision in such a lawsuit. Matches that turned only on unrelated uses of the search words are excluded and are never presented as FIFA cases; they are listed separately on the library page so the screening remains auditable.

Record types used here (Additional case history; Administrative consent order; City enforcement lawsuit settlement; Direct FIFA ruling; Enforcement matter; New case group; Related procedural decision) are research classifications applied during review, not labels assigned by any court.

How documents are handled

  • 35 original PDFs are preserved unmodified, with SHA-256 hashes shown next to the download where the research recorded one.
  • 44 reading copies are offered as extracted, readable text. Reading copies are labeled as such and are not original PDFs.
  • Downloads point to reading copies recorded in the research records, not to raw partial web captures, and raw research dumps are not published here.
  • Nothing here is a certified copy. Court opinions that were reproduced by a third-party service keep that source label, and official court and agency links are preserved on every record.

Known gaps in the saved documents

  • Iams v 10X Mgt. LLC: the original PDF is not saved locally; the official source link is provided instead.
  • Varn v. Orchestrade: the initial 2020 capture is partial and is not published as a document; the 2022 opinion is saved as readable text.
  • Monzano-Moreno v. Libqual Fence: the saved document is a magistrate judge’s report and recommendation. Later opinions cite its adoption, but the adoption order itself was not obtained.
  • DCWP / Splashlight: the official announcement was reviewed; the signed agreement is not saved and payment completion is unverified.
  • Petty v. Maison Hospitality Furnishings: the original 32-page court PDF of Document 26 is now saved unmodified, together with text extracted page by page from that PDF, so page citations on the case page refer to the court document’s own pages. Later appellate or docket history has not been checked.
  • Maplebear Inc. v. City of New York: the original PDF is saved. A notice of interlocutory appeal from the opinion appears on the public docket; no appellate or stay outcome has been checked here.

Citation connections

Citation contexts were extracted from the retained opinions and reviewed by hand. The site shows three different things, and does not blur them:

  • Verified discovery trails — how a newly added matter was actually located.
  • Quoted citations — the citing opinion’s own words are saved here, with the page of the saved document they appear on. A quoted citation records what one decision said about another; it is not a statement that the cited reading is correct or binding.
  • Pending citation candidates — selected candidate links between matters already in the collection, reconciled to a target in this library but not cleared as verified precedent, and implying no endorsement.

Only candidates that reconcile to a matter in this library are linked. General procedural, employment and contract authorities were not treated as FIFA cases merely because they were cited. This was a first citation pass, not exhaustive citation clearance.

Open leads, not counted

  • Sylvestre v Diversified Psychological Services PLLC, 2019 WL 3202388

    Expressly discussed as a FIFA decision in Clement (2020), p. 7. Its own opinion has not been obtained despite targeted public searches. Pending / unverified — not included in verified counts.

  • Whitfield, Kings County 523750/2021 (May 23, 2023, NYSCEF 35; July 27, 2023, 2023 WL 4867834)

    Related history cited in the retained 2025 opinion. Not counted as an additional independent FIFA dispute.

  • Chen, index 162408/2019, April 30, 2020

    Earlier CPLR 3213 proceeding cited by Chen (2022). Related-history lead; not separately pulled or counted.

  • Monzano-Moreno adoption order, February 23, 2021 (2021 WL 688295)

    Adoption is reported by later judicial opinions; the adoption order itself is not in the saved collection.

Coverage limits

This is a collection of publicly located matters. It omits cases without published opinions, private arbitration outcomes, confidential settlements and most agency complaints. An agency complaint is not automatically a court case, and a single enforcement settlement covering many freelancers is one matter, not many cases.

No comprehensive later-treatment research, full-docket retrieval or payment verification was performed. Case status here means the latest document collected, not a docket-status check. Claim amounts that were not independently extracted are marked unknown. Money awarded on other legal grounds is not described as FIFA recovery. Do not infer success rates or average recoveries from this sample.

Nothing on this site is legal advice, and using it creates no attorney–client relationship. Return to the case library.