New York Consolidated Laws

N.Y. Labor Law § 197 (2026)

Civil penalty

✓ current as of May 2026

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§ 197. Civil penalty. Any employer who fails to pay the wages of his
employees or shall differentiate in rate of pay because of protected
class status, as provided in this article, shall forfeit to the people
of the state the sum of five hundred dollars for each such failure, to
be recovered by the commissioner in any legal action necessary,
including administrative action or a civil action.

Notes of Decisions

Cited in 8 cases (4 in the last 5 years), 1989–2024 · leading case: Chu Chung v. New Silver Palace Restaurant, Inc., 272 F. Supp. 2d 314 (S.D.N.Y. 2003).

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Chu Chung v. New Silver Palace Restaurant, Inc., 272 F. Supp. 2d 314 (S.D.N.Y. 2003). “Since the plaintiffs here are within the class for whose especial benefit the statute was enacted, there is an indication of legislative intent to allow employees a private right of action against their employers, and implying such a remedy for the plaintiffs is consistent with…”

P & L Grp., Inc. v. Garfinkel, 150 A.D.2d 663 (N.Y. App. Div. 1989). “Labor Law §§ 197 and 198 reflect a strong legislative policy aimed at protecting an employee’s right to wages earned.”

Angello v. Labor Ready, Inc., 859 N.E.2d 480 (NY 2006). “The next amendment to the statute, codified as Labor Law § 197 in 1921, provided that there could be no “off-set in behalf of the employer against wages” for provisions, clothing and groceries (see L 1921, ch 50).”

Hertzoff v. Diaz, 533 F. Supp. 2d 470 (S.D.N.Y. 2008). “See N.Y. Lab. Law §§ 197 , 198-a. Thus, any illegal deduction from wages qualifies as material.”

Ersin Konkur v. Utica Academy of Sci. Charter Sch. (NY 2022). “The Labor Law’s overarching goal is to protect employees from wage law violations (see generally Cammon v City of New York, 95 NY2d 583, 590 [2000]; see also P & L Group v Garfinkel, 150 AD2d 663, 664 [2d Dept 1989] [“Labor Law §§ 197 and 198 reflect a strong legislative policy…”

Acrisure, LLC v. Hudak (W.D. Mich. 2023). “See N.Y. LAB. LAW §§ 197 , 198-a. Thus, any illegal deduction from wages qualifies as material.”

Charles v. United States of Artizia Inc. (S.D.N.Y. 2024). “Similarly, the Labor Law continues to provide for civil and criminal penalties for violations of article 6 (see Labor Law §§ 197, 198, 218; AHA Sales, Inc.”

Grant v. Global Aircraft Dispatch, Inc., 2024 NY Slip Op 00183 (N.Y. App. Div. 2024). “Similarly, the Labor Law continues to provide for civil and criminal penalties for violations of article 6 ( see Labor Law §§ 197, 198, 218; AHA Sales, Inc.”

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