Blye v. Globe-Wernicke Realty Co., 33 N.Y.2d 15 (1973)
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An innkeeper’s lien law that permits the seizure of a guest’s property without prior notice and an opportunity for a hearing violates the due process clause of the Fourteenth Amendment.
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Summary
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Judy Blye, a resident of the Van Rensselaer Hotel, was locked out of her room for nonpayment of one week’s charges. The hotel, acting under the New York innkeeper’s lien law, seized her personal property without notice or a hearing. Blye sued, arguing the law was unconstitutional. The New York Court of Appeals reversed the lower court’s dismissal, holding that the innkeeper’s lien law violated due process because it allowed for seizure of property without notice and a hearing, and that the actions of the hotel constituted state action for purposes of the Fourteenth Amendment.
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Facts
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Judy Blye resided at the Van Rensselaer Hotel in Manhattan.
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She was locked out of her room for failing to pay $60.60 for one week’s charges.
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The hotel seized her personal property, valued at approximately $700, pursuant to Section 181 of the Lien Law (the innkeeper’s lien law) without providing any prior notice or opportunity for a hearing.
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Blye was left only with the clothes she was wearing and her purse containing identification and some small change.
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Procedural History
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Blye initiated an action seeking a declaratory judgment that Section 181 of the Lien Law was unconstitutional, a permanent injunction against its enforcement, and damages for mental distress.
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Special Term dismissed the action, relying on Waters & Co. v. Gerard, which had upheld a predecessor statute against a due process challenge.
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The Appellate Division affirmed the Special Term’s decision.
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The appeal reached the New York Court of Appeals as a matter of right based on constitutional grounds.
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Issue(s)
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1. Whether the innkeeper’s lien law constitutes state action for purposes of the Fourteenth Amendment’s due process clause when it is invoked by a private actor (the hotel)?
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2. Whether the innkeeper’s lien law violates the due process clause of the Fourteenth Amendment by allowing the seizure of a guest’s property without prior notice and opportunity for a hearing?
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Holding
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1. Yes, because the execution of a lien traditionally has been the function of the Sheriff and because innkeepers are possessed of certain powers by virtue of section 181 of the Lien Law.
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2. Yes, because procedural due process requires notice and an opportunity for a hearing before the State may deprive a person of a possessory interest in his property, and the statute does not serve an important governmental or general public interest.
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Court’s Reasoning
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The court addressed whether the seizure by the hotel constituted “State action” necessary to trigger due process protections. It acknowledged that private conduct generally does not implicate due process, but that private actions can become state actions when private actors perform traditionally public functions or when their actions are clothed with the authority of state law.
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The court reasoned that the execution of a lien traditionally falls under the purview of the Sheriff. Therefore, when an innkeeper executes on a lien, it constitutes state action. Moreover, the innkeeper’s power to seize property under the Lien Law cloaks their actions with state authority.
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Turning to due process, the court emphasized that procedural due process requires notice and a hearing before the State deprives a person of property. The Court stated, “Procedural due process requires notice and an opportunity for a hearing before the State may deprive a person of a possessory interest in his property.”
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The court distinguished the innkeeper’s lien from situations justifying summary seizure, such as protecting a governmental interest or responding to an emergency. Here, “no more than private gain is directly at stake.” The statute affected individuals, such as the plaintiff, who resided in hotels and could be severely impacted by summary seizure.
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The court found the statute overly broad, permitting “the unchecked summary seizure of a guest’s property without regard to the validity of the particular claim and without regard to whether the particular guest is likely to remove or conceal himself and his property if given notice and opportunity for a hearing.”
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Balancing the interests, the court concluded that