People v. St. Agatha Home for Children, 47 N.Y.2d 46 (1979)
When a county, pursuant to state law, establishes a facility to fulfill its statutory obligations, that decision preempts conflicting local zoning ordinances.
Summary
St. Agatha Home for Children and one of its employees were convicted of violating a local zoning ordinance by operating a nonsecure detention center in an area zoned for single-family occupancy. The Court of Appeals reversed, holding that Section 218-a of the County Law authorized and required the county to provide adequate facilities for persons in need of supervision, even if it conflicted with local ordinances. Since the facility was established at the county’s behest, approved by the county, and funded by the county, the local zoning ordinance could not overrule the county’s decision.
Facts
St. Agatha Home for Children, a private child care organization, and one of its employees, were charged with violating a local zoning ordinance. They were operating a nonsecure detention center for persons in need of supervision (PINS). The location was in an area zoned for one-family occupancy. The facility was established at the request of the county, its location was approved by the county, and it was funded by and through the county.
Procedural History
The defendants were convicted at the trial level. The Appellate Term set aside the convictions. The People appealed to the New York Court of Appeals.
Issue(s)
Whether Section 218-a of the County Law, which requires counties to provide non-secure detention facilities, preempts local zoning ordinances that would otherwise prohibit such facilities in certain areas.
Holding
Yes, because Section 218-a of the County Law authorizes and requires a county to provide adequate facilities of the type described despite any conflicting law or local ordinance.
Court’s Reasoning
The Court focused on the language of Subdivision B of Section 218-a of the County Law, which states that each board of supervisors “shall provide or assure the availability of conveniently accessible and adequate non-secure detention facilities… notwithstanding any other provision of law.” The Court interpreted this as both authorizing and requiring a county to provide adequate facilities, even if conflicting with local laws. The Court emphasized the uncontroverted evidence that the facility was established at the county’s request, its location approved by the county, and funded by the county. The court stated, “The county having determined, as it is authorized to do by the statute, to fulfill its obligation through the vehicle of privately operated homes, that decision may not be overruled by application of a local zoning ordinance.” The court explicitly stated that, having chosen to litigate this matter as a criminal proceeding, the People needed to prove all elements of the offense beyond a reasonable doubt, which they failed to do here.