City of Rye v. Metropolitan Transportation Authority, 24 N.Y.2d 627 (1969)
A “special act” of the legislature, as required by the New York Constitution for creating public corporations with the power to contract debt and collect fees, means a specific legislative enactment establishing the corporation, not necessarily limited to a single subject or precluding the inclusion of other matters related to the corporation’s powers and duties.
Summary
The City of Rye and the Town of Oyster Bay challenged the constitutionality of a 1967 New York law that empowered the Metropolitan Transportation Authority (MTA) to construct bridges, arguing it violated the constitutional requirement that public corporations be created by a “special act” of the legislature. The plaintiffs contended that the law dealt with multiple subjects and was thus not a “special act.” The Court of Appeals reversed the lower court’s decision, holding that the law was a valid “special act” because it specifically created or continued the MTA and the bridge-building power was incidental to its corporate function. The court emphasized the legislative intent to require direct legislative creation, not delegation to administrative bodies.
Facts
In 1967, the New York Legislature amended the Public Authorities Law, making changes to the Metropolitan Transportation Authority (MTA) and creating the Niagara Frontier Transportation Authority. Specifically, the amendment authorized the MTA to construct two bridges over Long Island Sound, one connecting Oyster Bay to Westchester County near the City of Rye. The City of Rye and the Town of Oyster Bay challenged the law, claiming it violated Article X, Section 5 of the New York Constitution, which requires public corporations with the power to contract debt and collect fees to be created by a “special act” of the legislature.
Procedural History
The Supreme Court, Special Term, granted judgment for the City of Rye and the Town of Oyster Bay, declaring portions of the 1967 law unconstitutional. The MTA and state officers appealed directly to the New York Court of Appeals based on constitutional grounds. The Niagara Frontier Transportation Authority appeared as amicus curiae, concerned about the implications for its own creation. The Court of Appeals reversed the Special Term’s decision, upholding the law’s constitutionality.
Issue(s)
1. Whether the 1967 law creating or continuing the Metropolitan Transportation Authority (MTA) constitutes a “special act” of the legislature as required by Article X, Section 5 of the New York Constitution.
2. Whether the 1967 law is an unconstitutional “local bill” embracing more than one subject in violation of Article III, Section 15 of the New York Constitution.
3. Whether the 1967 law violates Article IX, Section 2(b)(2) of the New York Constitution, which governs the enactment of statutes relating to the property, affairs, or government of local governments.
Holding
1. Yes, because the term “special act” means a particular creative enactment by the legislature establishing the public corporation. It does not mean that only one subject could be stated in the statute or that the legislature could not deal additionally with other matters, including the kinds of powers to be exercised or duties to be performed by the public corporation thus created.
2. No, because the law deals broadly with state purposes and policies and is not a “local bill” within the meaning of Article III, Section 15.
3. No, because the law authorizes a state corporation to build a state bridge and locates a state highway, which does not relate to the property, affairs, or government of the Town of Oyster Bay within the meaning of Article IX, Section 2(b)(2).
Court’s Reasoning
The Court reasoned that the constitutional provision requiring a “special act” aimed to prevent the legislature from delegating the creation of public authorities to administrative officers or local governments, ensuring direct legislative oversight. The court emphasized that the term “special act” means a particular creative enactment establishing the corporation, not a limitation on the subjects the act can address. The court considered the historical background of Article X, Section 5, originating from the 1938 Constitutional Convention, which sought to address the proliferation of public authorities after 1927. The Court stated, “Thus, the purpose was to prevent the Legislature from allowing the creation of public authorities in the manner in which, since 1846, it had been required to do with private corporations by a general statute, and require the Legislature itself to create them specifically by ‘special act’.” It highlighted the consistent legislative practice of creating public corporations through amendments to the Public Authorities Law, citing the New York State Thruway Authority as an example. The Court also rejected the argument that the law was an unconstitutional “local bill,” finding it concerned state purposes, not local affairs. Regarding the Home Rule provision, the court stated, “This location of State highways has nothing whatever to do with the property, affairs or government of the Town of Oyster Bay.” The Court also dismissed any purported concessions made by counsel at Special Term, stating that such concessions could not bind the court on the constitutionality of a legislative act. The court noted, “no concession or admission in a pleading or affidavit by a public officer or his counsel on the validity of an act duly passed by the Legislature will bind the court to hold it unconstitutional”.