Koerner v. State, 62 N.Y.2d 444 (1984)
A civil action against the State for discriminatory practices under the Human Rights Law is governed by a three-year statute of limitations and can be brought in Supreme Court, not exclusively in the Court of Claims.
Summary
Koerner sued the State, alleging discriminatory termination based on a physical disability in violation of the Human Rights Law. The State moved to dismiss, arguing a four-month statute of limitations applied and that the claim should be pursued in the Court of Claims. The Court of Appeals reversed the lower courts, holding that the three-year statute of limitations applies to Human Rights Law claims against the State, and the Supreme Court has subject matter jurisdiction because the Legislature implicitly consented to suit outside the Court of Claims to fully address human rights violations.
Facts
Koerner applied for a food service worker position at a state psychiatric center and was hired in April 1981. His employment was immediately terminated after a medical examination revealed poor vision. Koerner believed his vision would not impair his ability to perform the job. In February 1982, he sued for reinstatement, back pay, and damages, alleging discrimination based on physical disability in violation of the Human Rights Law.
Procedural History
The Supreme Court granted the State’s motion to dismiss, concluding the four-month statute of limitations applied and that the monetary claim belonged in the Court of Claims. The Appellate Division affirmed. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether the statute of limitations applicable to civil actions against the State pursuant to the Human Rights Law is three years or four months.
2. Whether a plaintiff pursuing a claim for monetary relief against the State under the Human Rights Law must do so exclusively in the Court of Claims.
Holding
1. Yes, the statute of limitations is three years because a judicial action for discriminatory discharge commenced pursuant to the Human Rights Law is governed by a three-year statute of limitations under CPLR 214(2).
2. No, the claim does not need to be pursued exclusively in the Court of Claims because the Legislature has provided implicit consent that the State can be sued in a forum other than the Court of Claims when it enacted the Human Rights Law.
Court’s Reasoning
The Court of Appeals reasoned that its decision in Murphy v. American Home Prods. Corp. established that a three-year statute of limitations applies to Human Rights Law claims. The State argued that Solnick v. Whalen and Press v. County of Monroe mandate a four-month limitation because the action challenges state action. However, the Court distinguished those cases, noting they involved challenges to governmental determinations reviewable via Article 78 proceedings, whereas Koerner’s claim arises directly under the Human Rights Law. The court stated, “When a specific limitations period is clearly applicable to a given action, there is no need to ascertain whether another form of proceeding is available for resolution of the dispute.”
Furthermore, the Court found no legislative intent to treat public employers more favorably under the Human Rights Law. The Court stated, “Clearly, the elimination of discrimination in the provision of basic opportunities is the predominant purpose of this legislation; all the more invidious is such discrimination when it is practiced by the State.” The Court emphasized the broad, ameliorative purposes of the Human Rights Law, citing Executive Law § 300, which states the provisions of the Human Rights Law must be construed liberally for the accomplishment of their purposes.
Regarding the forum, the Court noted the State Division of Human Rights can award damages against the State, enforceable without the Court of Claims. The Court reasoned that granting the Division such power implies a legislative waiver of immunity to suit outside the Court of Claims. Requiring separate lawsuits for equitable relief (unavailable in the Court of Claims) and damages would be inefficient and contradict the Human Rights Law’s purpose. Because the Court of Claims lacks the power to order equitable relief such as reinstatement, the Court reasoned that interpreting the law to require actions against the state to be brought in the Court of Claims would create a “manifestly unfair result” and undermine the purpose of the Human Rights Law.