District Council 37 had charged in a formal grievance that its workers in 2010 couldn't get to work because subways and buses weren't running.
Gaines said language in the DC 37 contract excuses lateness caused by "a major failure of public transportation." But she did not find evidence that the contract allowed a missed workday under those circumstances.
DC 37 Director Lillian Roberts said she looked forward to working with the city on a future contingency plan. She didn't directly address the finding.