Matter of Brooklyn v. Board of Education, 166 N.Y. 330 (1901)

When interpreting seemingly conflicting statutes arising from municipal consolidation, courts should seek the legislature’s general purpose and construe each provision to conform to that intent, promoting harmonious operation of the whole.

Summary

This case involves a dispute over the apportionment of the general school fund among the borough school boards of New York City following consolidation. The Brooklyn school board sought a writ of mandamus to compel the Board of Education to apportion the fund according to a specific section of the new city charter. Other borough school boards argued that prior actions by the Board of Estimate and Apportionment were conclusive. The Court of Appeals affirmed the lower court’s order, holding that the charter’s provisions for implementing the new school system should be harmonized, and any temporary imbalances in funding would be corrected in subsequent budgets.

Facts

Following the consolidation of several municipalities into New York City, a dispute arose regarding the distribution of the general school fund for 1898. The Brooklyn school board sought its share based on pupil attendance, as outlined in the new city charter. Other borough school boards contended that Brooklyn was receiving a disproportionately large share, exceeding what it had contributed in taxes for school purposes in 1897. They argued this violated a provision requiring funds to be used