## Facts

- A construction company entered into multiple municipal public works contracts requiring payment of prevailing wages.
- The company hired Carlos Huerta to perform construction work after requesting proof of work eligibility.
- Huerta provided an alien registration card and a Social Security card; the documents were later discovered to be false, which Huerta did not dispute.
- After Huerta’s employment ended, he sued for unpaid prevailing wages allegedly owed under the public works contracts.
- The employer sought summary judgment, asserting the employment contract was illegal and that Huerta’s misconduct barred relief under unclean hands.

## Issues

1. Whether Huerta’s use of false work-authorization documents made the employment contract illegal and unenforceable, precluding recovery of unpaid prevailing wages.
2. Whether Huerta’s misrepresentation constituted unclean hands barring recovery, including equitable relief, for wages for work performed.

## Decision

- The appellate court affirmed the denial of the employer’s summary judgment motion as to Huerta’s claims.
- The court held that neither the employment contract nor the work performed was illegal for purposes of wage recovery.
- The court held that unclean hands did not bar Huerta’s wage claim because the misconduct did not cause injury to the employer in relation to the wage dispute.

## Legal Principles

- Illegal contracts are generally unenforceable, but an employment relationship is not rendered unenforceable for wage-payment purposes solely because a worker used false work-authorization documents.
- As between an employer and an undocumented worker, a contract of employment exists under which the worker is entitled to be paid for work actually performed, including contractually or statutorily required wages.
- Unclean hands requires misconduct directly related to the claim and resulting in injury to the party asserting the defense; absent such injury, the defense will not defeat earned-wage claims.
- An employer that benefited from a worker’s labor cannot avoid prevailing-wage obligations through illegality or equitable defenses based only on the worker’s immigration-related misrepresentation.

## Conclusion

The court allowed the prevailing-wage action to proceed, holding that false work-authorization documents did not make the employment contract unenforceable or bar wage recovery under illegality or unclean hands where the employer was not harmed in the wage dispute and had received the benefit of the work performed.


Jara v. Strong Steel Door, Inc., 58 A.D.3d 600, 871 N.Y.S.2d 363 (2d Dep’t 2009)