Barry v. New York State Racing and Wagering Board, 54 N.Y.2d 857 (1981)
An administrative agency’s interpretation of its own regulations is entitled to deference, and will not be disturbed unless arbitrary and capricious.
Summary
The New York Court of Appeals affirmed a decision upholding the disqualification of a racehorse due to incorrect weight. The court deferred to the New York State Racing and Wagering Board’s interpretation of its rule requiring written objections, finding that the rule applied to objections from outside parties, not actions initiated by track stewards themselves. The court emphasized the owner’s responsibility for ensuring the horse’s correct weight and found no violation of the Board’s regulations based on the stewards’ actions.
Facts
Petitioner’s horse, “Blazin’ C,” won the fifth race at Aqueduct Racetrack on January 18, 1980.
The horse was subsequently disqualified for carrying an incorrect weight, specifically, receiving a five-pound weight allowance to which it was not entitled based on its racing history.
An assistant racing secretary orally notified the stewards of the weight impropriety based on information from a jockey’s agent.
The stewards took action based on this information, disqualifying the horse.
Procedural History
The New York State Racing and Wagering Board upheld the disqualification.
The Appellate Division affirmed the Board’s decision.
The case was appealed to the New York Court of Appeals.
Issue(s)
Whether the New York State Racing and Wagering Board erred in disqualifying “Blazin’ C” as the winner.
Whether the Board failed to follow its own rule requiring objections to be made in writing (9 NYCRR 4039.11) when the stewards acted on information received orally.
Holding
1. No, because the ultimate responsibility for ensuring a horse carries the correct weight rests with the owner.
2. No, because the Board reasonably interpreted the written objection rule as applying to objections from external parties (e.g., owners, trainers, jockeys), not to actions initiated by the track stewards themselves.
Court’s Reasoning
The court emphasized the owner’s responsibility for ensuring the horse carries the correct weight, citing 9 NYCRR 4033.7. Therefore, the owner could not blame the racing secretary for the error.
Regarding the written objection rule (9 NYCRR 4039.11), the court deferred to the Board’s interpretation. The court reasoned that agencies are best positioned to interpret their own regulations.
The Court found that the purpose of the rule, as interpreted by the Board, is to