City of Amsterdam v. Helsby, 37 N.Y.2d 19 (1975)
The New York State Legislature can constitutionally delegate to the Public Employment Relations Board (PERB) and arbitration panels the authority to resolve collective bargaining impasses between municipalities and their police and fire departments through compulsory and binding arbitration, as this does not violate the Home Rule provisions of the New York Constitution or constitute an improper delegation of legislative power.
Summary
The cities of Amsterdam and Buffalo challenged the constitutionality of amendments to Section 209 of the Civil Service Law, which mandated compulsory and binding arbitration for disputes between municipalities and their police and fire departments. The cities argued these amendments violated the Home Rule provisions of the New York Constitution and improperly delegated legislative power to arbitration panels. The Court of Appeals held that the amendments were constitutional, finding that they constituted a general law applicable to all municipalities and that the delegation of authority to PERB and arbitration panels was permissible with sufficient safeguards and standards.
Facts
The City of Amsterdam and the collective bargaining representative for its policemen and firemen reached an impasse in negotiations. The union sought compulsory and binding arbitration under the amended Section 209 of the Civil Service Law. The City of Amsterdam refused to participate and obtained a court order preventing arbitration, arguing the amendments were unconstitutional.
Similarly, the City of Buffalo and the unions representing its policemen and firemen also reached an impasse. The unions petitioned PERB to refer the disputes to an arbitration panel. The City of Buffalo then filed an action seeking a judgment declaring Section 209, as amended, unconstitutional.
Procedural History
In City of Amsterdam v. Helsby, the trial court initially granted a temporary restraining order and then a final judgment preventing arbitration and declaring the amendments unconstitutional. The City of Amsterdam appealed directly to the Court of Appeals.
In City of Buffalo v. New York State Public Employment Relations Bd., the trial court granted a judgment declaring the amendments constitutional and valid, dismissing the city’s complaint. The City of Buffalo appealed directly to the Court of Appeals.
Issue(s)
1. Whether the amendments to Section 209 of the Civil Service Law, mandating compulsory and binding arbitration for disputes between municipalities and their police and fire departments, violate the Home Rule provisions of the New York Constitution?
2. Whether the Legislature unconstitutionally delegated its legislative authority to the arbitration panel by enacting the amendments to Section 209 of the Civil Service Law?
Holding
1. No, because the amendments constitute a general law applicable to all cities, and the Home Rule powers of municipalities are subordinate to general laws enacted by the Legislature.
2. No, because the Legislature can delegate power with reasonable safeguards and standards to an agency or commission to administer an enactment, and the Legislature established specific standards for the arbitration panel to follow.
Court’s Reasoning
The Court reasoned that the Home Rule provisions of the New York Constitution allow local governments to regulate the hours of work and compensation of their employees only to the extent that such regulation is not inconsistent with any general law enacted by the Legislature. Because the amendments to Section 209 are “general laws,” applicable to all cities, the local governments must yield to the arbitration panel’s decisions once an impasse is reached. A “general law” is defined as “[a] law which in terms and in effect applies alike to all counties, all counties other than those wholly included within a city, all cities, all towns or all villages.” (NY Const, art IX, § 3, subd [d], par [1].)
Regarding the delegation of legislative authority, the Court stated, “there is no constitutional prohibition against the legislative delegation of power, with reasonable safeguards and standards, to an agency or commission established to administer an enactment.” The Legislature delegated its authority to PERB and arbitration panels with specific standards that the panels must follow, as outlined in Civil Service Law § 209, subd 4, par [c], cl [v]. Therefore, the delegation was proper and reasonable.
The Court also addressed the City of Amsterdam’s arguments regarding the power of taxation and the one-man-one-vote principle, finding them to be without merit.