Matter of Hodes v. Axelrod, 56 N.Y.2d 931 (1982)
A certificate of relief from disabilities, issued pursuant to Article 23 of the Correction Law, bars the automatic revocation of a license, including a nursing home operating certificate, even upon conviction of an industry-related felony.
Summary
This case addresses the conflict between Public Health Law § 2806(5), which mandates automatic revocation of nursing home certification upon felony conviction, and Correction Law § 701, which prevents automatic license revocation for individuals with certificates of relief from disabilities. The Court of Appeals held that the latter statute controls, preventing automatic revocation where certificate holders are involved. Despite acknowledging the problematic outcome, the court deferred to the legislature to resolve the statutory conflict, emphasizing its role in interpreting existing law rather than creating new policy.
Facts
The petitioners, nursing home operators, were convicted of industry-related felonies. They had previously been issued certificates of relief from civil disabilities under Article 23 of the Correction Law.
Procedural History
The respondent, presumably a state agency responsible for licensing, sought to revoke the petitioners’ nursing home operating certificates based on their felony convictions. The lower courts’ decisions are not explicitly stated in the Court of Appeals memorandum opinion, but the Court of Appeals reversed the judgments of the Appellate Division, granted the petitions, and annulled the determinations, indicating that the lower courts had upheld the revocations.
Issue(s)
Whether Correction Law § 701, which prohibits automatic license revocation for individuals holding certificates of relief from disabilities, supersedes Public Health Law § 2806(5), which mandates automatic revocation of nursing home operating certificates upon conviction of an industry-related felony.
Holding
Yes, because Correction Law § 701 bars automatic revocation of a license where the holder has been issued a certificate of relief from disabilities pursuant to article 23 of the Correction Law.
Court’s Reasoning
The Court based its decision on a strict interpretation of the existing statutes, specifically Correction Law § 701. The court emphasized its role is to apply the law as it exists, stating, “Consistent with our general rule of appellate review, we decide these cases on the basis of the law which exists today.” Because the petitioners possessed certificates of relief from disabilities, § 701 directly barred the automatic revocation of their licenses, notwithstanding the conflicting provision in the Public Health Law. The Court explicitly acknowledged the problematic outcome of this statutory interplay, stating, “The unfortunate result produced by the interrelationship of subdivision 5 of section 2806 of the Public Health Law and section 701 of the Correction Law does not go unnoticed by this court.” However, it declined to resolve the conflict through judicial interpretation, deferring to the legislature to amend the statutes and address the policy implications. The court reasoned that any “amelioration of the problem…is properly left to the Legislature.” The decision reflects a separation-of-powers approach, leaving policy corrections to the legislative branch.