85 N.Y.2d 209 (1995)
When a statute’s legislative history demonstrates a clear intent to limit agency discretion, courts should not defer to an agency’s interpretation that contravenes that intent, even if the statute’s operative terms are not explicitly defined.
Summary
This case concerns the interpretation of New York City Administrative Code § 14-103(b)(2), which mandates the appointment of police officers to detective status after 18 months of performing detective duties. The Police Commissioner attempted to limit the scope of this provision through departmental orders. The Court of Appeals held that the statute’s legislative intent was to eliminate the Commissioner’s discretion in defining detective duties, and thus the departmental orders were invalid. The Court emphasized that deference to an agency’s interpretation is inappropriate when it undermines the statute’s remedial purpose.
Facts
Several New York City police officers were temporarily assigned to perform detective duties for periods exceeding 18 months. The Administrative Code § 14-103(b)(2) states that officers performing detective duties for more than 18 months must be appointed as detectives. The New York City Police Department issued Interim Order 61, which restricted the application of § 14-103(b)(2) to specific types of investigative assignments. This order effectively prevented many officers performing long-term investigative work from receiving detective appointments.
Procedural History
The petitioners, police officers affected by Interim Order 61, initiated a CPLR article 78 proceeding challenging the validity of the Police Department’s orders. The Supreme Court granted the petition, directing the City to comply with the statute. The Appellate Division affirmed this decision and certified the question of the ruling’s propriety to the Court of Appeals.
Issue(s)
Whether the Police Commissioner retains discretion to define the term “duties of a detective” in Administrative Code § 14-103(b)(2) and thereby limit the statute’s application, despite the statute’s mandate for appointment after 18 months of such duty.
Holding
No, because the legislative intent behind the 1990 amendment to Administrative Code § 14-103(b)(2) was to eliminate the Police Commissioner’s discretion in determining who qualifies as a detective after performing the relevant duties for more than 18 months.
Court’s Reasoning
The Court of Appeals determined that the legislative intent of the 1990 amendment was to curtail the Police Commissioner’s discretion in detective appointments. The Court reviewed the legislative history, finding that the amendment was enacted to address the inequity of officers performing detective work without receiving the corresponding benefits and recognition. The Court noted that the terms