Hotel Dorset Co. v. Trust for Cultural Resources of City of New York, 46 N.Y.2d 358 (1978)
Legislation that benefits a specific cultural institution is constitutional if it is part of a general scheme applicable statewide to any institution that meets the specified criteria, and the criteria are reasonably related to a legitimate public purpose.
Summary
Hotel Dorset Co. challenged the constitutionality of the New York State Cultural Resources Act (SCRA) and the New York City Cultural Resources Act (CCRA), arguing they were special legislation designed solely for the benefit of the Museum of Modern Art (MoMA). The legislation allowed for the creation of cultural trusts to assist cultural institutions by developing combined-use facilities (cultural and commercial spaces), with tax equivalency payments from the commercial space supporting the cultural part. The Court of Appeals reversed the Appellate Division, holding that the legislation was constitutional because it established a general framework applicable to any institution meeting the specified criteria, and those criteria were related to a public purpose. The Court emphasized the legislative findings supporting the preservation and fostering of cultural institutions.
Facts
The Museum of Modern Art sought to expand its facilities by constructing a combined-use facility: a museum wing with condominium apartments above it. The Trust for Cultural Resources of the City of New York, created under the CCRA, planned to acquire land for this project through condemnation. The Hotel Dorset Co., a taxpayer owning property and air rights contiguous to the museum, challenged the enabling legislation (SCRA and CCRA). The Hotel Dorset argued the legislation was special, benefiting only MoMA, because it contained specifications that only MoMA currently met (e.g., owning over 50,000 square feet of property for five years and having average annual admissions of at least 500,000 people).
Procedural History
Special Term ruled in favor of the defendants (the Trust), finding the statutes constitutional. The Appellate Division reversed, holding that the SCRA was a special law applicable only to MoMA, violating several provisions of the New York State Constitution. The Court of Appeals reversed the Appellate Division and reinstated the Special Term’s order, declaring the legislation constitutional.
Issue(s)
Whether the New York State Cultural Resources Act (SCRA) and the New York City Cultural Resources Act (CCRA) constitute unconstitutional special legislation in violation of the New York State Constitution.
Holding
No, because the SCRA and CCRA establish a general legislative framework applicable to any cultural institution that meets the specified criteria, and those criteria are reasonably related to the legitimate public purpose of preserving and supporting cultural institutions.
Court’s Reasoning
The Court reasoned that although the statutory specifications fitted MoMA’s present statistics, there was no showing that other institutions could not, in time, meet them as well. The court emphasized that absent such a showing, a court is in no position to hold the legislation unconstitutional as special legislation applicable only to a single enterprise. The Court highlighted the detailed legislative findings supporting the statutes’ purposes, noting that the Legislature had clearly stated the plans comprised general legislation applicable statewide to institutions that own or will own enough property, serve the needs of many people, and generate enough interest to warrant recognition as institutions of significant community value. The Court stated, “Courts are required to exercise a large measure of restraint when considering highly intricate and imaginative schemes for public financing or for public expenditures designed to be in the public interest…[they] must operate on the rule that it may not substitute its judgment for that of the body which made the decision.” The Court cited Wein v City of New York, stating, “Where, as here, the statutory scheme stays within the letter of the Constitution…then we should not strain ourselves to find illegality in such programs.” The Court applied the presumption that an act of the Legislature is constitutional, which can be upset only by proof persuasive beyond a reasonable doubt. The court also noted a further presumption that the Legislature has investigated and found facts necessary to support the legislation. The court distinguished Matter of Mayor of City of N.Y. [Elm St.], where a statute was deemed special because it revived condemnation awards but could only benefit one claimant due to the specific circumstances required for entitlement. The Court found that the statutes in the present case opened up a class of institutions to similar treatment. The court also found that the Board of Estimate approval requirement did not make the CCRA a special law and that the legislation’s subject matter (maintenance of cultural institutions) was of sufficient importance to the State generally, thus not a local law. The Court reasoned that even if the legislation presently affected only one museum, the preservation of that facility was of importance to the citizens of the state and the city alike. “Early was it said that an act need not apply to all persons, places or things in the State to be deemed general, if it apply to a class, entry into which was governed by conformity or compliance with specified conditions”