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Toledo wage-and-hour unit reports enforcement activity: contractor registration, stop-work orders and recovered taxes

5823331 · September 24, 2025
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Summary

The city's Wage and Hour Compliance division told the finance committee it has recovered more than $700,000 in unpaid employer taxes since its April 2024 launch, has issued stop-work orders in limited cases, and is promoting mandatory employee-posting requirements to address wage theft.

The Finance, Debt and Budget Oversight Committee received an update from the Wage and Hour Compliance division on enforcement of Toledo's wage-theft and contractor-registration ordinances.

Wage and Hour Compliance Commissioner Dan Morey summarized the division's activities since its establishment and outlined enforcement tools, outreach and several performance figures. "To date, we've had contact with over 600 employers in the aspect of performing our site visits," Morey said, citing weekend and evening inspections targeted at suspected illegal work.

Key points from the presentation: - Legal framework: Morey cited Toledo Municipal Code sections used by the unit, including a wage-theft ordinance (listed in the presentation as 545.22) and local ordinance references shown in the slides as 7 96 (employees' right to file a wage-theft complaint) and 7 98 (contractor and subcontractor registration requirement). - Staffing and start date: The unit was established on April 1, 2024, and currently has two dedicated employees (the commissioner and a wage enforcement coordinator, Mark Wilson). - Recoveries and caseload: The division said it has recovered over $700,000 in employer taxes and is averaging roughly $9,000 per week in recoveries. It has handled six employee-filed wage-theft complaints under the cited ordinance; roughly half of those resulted in wages returned to employees. The average recovery reported for the employee complaints was about $573 per person. - Contractor registration and stop-work orders: The unit enforces a contractor/subcontractor registration that building inspection uses as a condition to issue permits. Morey said the department has issued about a dozen stop-work orders from roughly 600 employer contacts, reserving that sanction for uncooperative or repeat violators. - Field coordination: Morey described a new procedure with building inspection to share photos and information and, in some cases, trigger a building stop-work order the same day rather than waiting for a separate inspector visit.

Morey emphasized an "education first" approach for employers who may be unaware of municipal tax requirements, especially out-of-state contractors arriving from states without municipal income taxes. "We want to bring those employers into compliance with some education," he said, but added that the ordinance includes fines and penalties for egregious or repeat violations.

Council members asked about trends and staffing. Vice Chair Driscoll asked whether the city plans additional full-time positions; the finance director said the administration may consider staffing changes in future budgets depending on caseload and compliance outreach needs.

Ending: Morey said the division will continue outreach to employers and require mandatory workplace postings starting Jan. 1 to inform employees of their rights under the ordinance.