Herkimer Memorial Hospital v. Whalen, 47 N.Y.2d 970 (1979)
Political subdivisions of a state lack standing to challenge the constitutionality of a state statute that restricts the subdivision’s governmental powers.
Summary
Herkimer Memorial Hospital, operated by a municipal corporation, challenged a determination by the New York State Department of Health that modified its operating certificate, requiring it to provide long-term care services instead of acute care. The hospital argued that the statute authorizing this modification was unconstitutional. The New York Court of Appeals held that as a political subdivision of the state, the hospital lacked standing to challenge the constitutionality of a state statute restricting its governmental powers. The Court reasoned that the hospital’s power to operate was delegated by the legislature, and it could not challenge the source of that power.
Facts
Herkimer Memorial Hospital was established by the appellant, a municipal corporation, under the authority of Section 126 of the General Municipal Law.
The State Department of Health, pursuant to Section 2806 of the Public Health Law, modified the hospital’s operating certificate.
The modified certificate stipulated that the hospital should provide long-term care services instead of operating as a 70-bed acute care facility.
The hospital challenged the Department of Health’s determination, arguing that the statute was facially unconstitutional.
Procedural History
The hospital challenged the determination in court.
The Appellate Division’s order was appealed to the New York Court of Appeals.
The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether a political subdivision of the State of New York has standing to challenge the constitutionality of a state statute that restricts the subdivision’s governmental powers.
Holding
No, because political subdivisions are part and parcel of the power delegated by the Legislature and cannot challenge the constitutionality of acts restricting their governmental powers.
Court’s Reasoning
The Court of Appeals relied on the principle that political subdivisions of a state lack the power to challenge the constitutionality of state statutes that restrict the subdivision’s governmental powers. The Court stated, “Inasmuch as political subdivisions of the State are powerless to challenge the constitutionality of an act of the Legislature that restricts the subdivision’s governmental powers, appellant lacks standing to maintain its constitutional challenge to section 2806 of the Public Health Law (see Town of Black Brook v State of New York, 41 NY2d 486, 488).” The hospital’s power to operate stemmed from a delegation by the state legislature, and therefore, the hospital could not challenge the validity of that delegation.
The Court emphasized that the hospital was established and operated as part of the power delegated by the Legislature to the appellant as a political subdivision.
This case is significant because it reinforces the established principle that political subdivisions cannot challenge the constitutionality of state laws that govern their powers, thus preserving the state’s legislative authority over its subdivisions.