City of New York v. Patrolmen’s Benevolent Ass’n, 89 N.Y.2d 380 (1996)
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A special law relating to a city’s property, affairs, or government is unconstitutional if enacted without a home rule message from the city, unless the subject matter is of sufficient importance to the State generally to render it a proper subject of State legislation; uniformity alone is insufficient justification.
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Summary
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The City of New York challenged the constitutionality of Chapter 13 of the Laws of 1996, which sought to give the Public Employment Relations Board (PERB) exclusive jurisdiction over negotiation impasses between the City and its police union (PBA). The City argued that the law violated the home rule provisions of the New York Constitution because it was a special law affecting the City’s affairs, enacted without a home rule message. The Court of Appeals affirmed the lower courts’ ruling, holding that Chapter 13 was unconstitutional because it was a special law that related to the City’s affairs and did not serve a substantial state interest that outweighed the City’s home rule rights. The purported goal of uniformity did not justify overriding home rule.
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Facts
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The collective bargaining agreement between the City of New York and the Patrolmen’s Benevolent Association (PBA) expired. When negotiations for a successor agreement stalled, the City requested the City’s Board of Collective Bargaining (BCB) appoint an impasse arbitration panel. Simultaneously, the State Legislature passed Chapter 13 of the Laws of 1996, which aimed to transfer jurisdiction over such impasses to the Public Employment Relations Board (PERB). New York City, under the Taylor Law (Civil Service Law § 212), had its own “mini-PERB”, the BCB, and procedures for resolving bargaining impasses. Chapter 13 was enacted without a home rule message from the City.
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Procedural History
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The City commenced an action seeking a declaration that Chapter 13 was unconstitutional for violating the home rule provisions of the New York Constitution. Supreme Court declared the law unconstitutional, and the Appellate Division affirmed. The Court of Appeals heard the appeal as of right due to the constitutional question.
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Issue(s)
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Whether Chapter 13 of the Laws of 1996 is unconstitutional because it was enacted in violation of the home rule requirements of Article IX, § 2 of the New York Constitution.
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Holding
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No, because Chapter 13 is a special law that relates to the property, affairs, or government of New York City and was not enacted to further a matter of sufficient importance to the State generally. Thus, its enactment without a home rule message from New York City renders the chapter law unconstitutional and unenforceable.
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Court’s Reasoning
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The Court of Appeals held that Chapter 13 was a special law as it applied only to New York City. It also related to the