Auerbach v. Board of Education, 86 N.Y.2d 198 (1995)
Education Law § 3107, governing accumulated sick leave payments upon separation for Teachers’ Retirement System (TRS) members, applies to both managerial and non-managerial members, based on the statute’s plain language.
Summary
This case concerns whether Education Law § 3107 applies to managerial employees within the New York City Teachers’ Retirement System (TRS) regarding payment for accumulated sick leave upon retirement. The petitioners, former managerial employees of the Board of Education, sought benefits under § 3107. The Board argued that Chancellor’s regulations limited sick leave payments for managers. The Court of Appeals held that § 3107 applies to all TRS members, including managers, based on the statute’s unambiguous language. The Court found no basis to exclude managerial employees and invalidated the conflicting Chancellor’s regulations.
Facts
Arthur Auerbach, Edward Aquilone, and Patricia Stryker were former employees of the Board of Education. Each was a member of the Teachers’ Retirement System (TRS). Prior to their retirement, each held non-pedagogical managerial titles but had previously held non-managerial positions. Upon retirement, they applied for retirement leave benefits under Education Law § 3107, which provides for payment of one-half of accrued, unused sick leave at their current full pay. The Board of Education, relying on the Chancellor’s regulations, sought to pay them at a lower rate for sick leave accrued in non-managerial positions and only one-third of sick leave accrued as managers, provided they maintained a minimum balance of 60 days.
Procedural History
Auerbach and Aquilone, and Stryker separately, initiated Article 78 proceedings challenging the Board’s calculation of their sick leave benefits. The Supreme Court dismissed the petitions, upholding the Chancellor’s regulations. The Appellate Division reversed, granting the petitions and holding that Education Law § 3107 applied to all TRS members, including managers. The Board of Education appealed to the Court of Appeals based on a double dissent in the Appellate Division.
Issue(s)
Whether Education Law § 3107, concerning payment for accumulated sick leave, applies to all members of the New York City Teachers’ Retirement System (TRS), including those holding managerial positions, or only to non-managerial, pedagogical members.
Holding
Yes, Education Law § 3107 applies to all members of the New York City Teachers’ Retirement System (TRS), including those holding managerial positions, because the statute’s language is clear and unambiguous in extending the benefit to all TRS members without qualification.
Court’s Reasoning
The Court of Appeals based its decision on the plain language of Education Law § 3107, which states that “employees of the board of education who are members of the New York city teachers’ retirement system” are entitled to sick leave benefits. The Court emphasized that these eligibility requirements were