66 N.Y.2d 354 (1985)
General Municipal Law § 802(1)(f) exempts contracts with voluntary non-profit associations from conflict-of-interest restrictions, but this exemption does not extend to contracts with labor unions when a municipal officer negotiating on behalf of the municipality has a direct financial interest in the contract’s outcome.
Summary
This case concerns a conflict of interest claim regarding a collective bargaining agreement between Suffolk County and the Suffolk County Chapter of the Civil Service Employees Association (CSEA). The plaintiff argued that the contract was void because the County’s chief negotiator, Farnetti, had a prohibited interest due to a local law linking his salary adjustments to those negotiated for CSEA members. The Court of Appeals affirmed the Appellate Division’s decision that the contract was valid, reasoning that CSEA fell under the voluntary non-profit association exception in General Municipal Law § 802(1)(f). However, a strong dissent argued that this exception should not apply to labor unions, and that Farnetti’s self-dealing constituted a clear violation of conflict-of-interest principles.
Facts
Suffolk County negotiated a collective bargaining agreement with CSEA bargaining units 2 and 6. Farnetti, the County Director of Personnel and Labor Relations, was the chief negotiator for the County. Local Law No. 4 of 1982 stipulated that all exempt County employees, including Farnetti, would receive the same salary adjustments as the CSEA members covered by the agreement. As a result, Farnetti’s salary was set to increase by 63% during the agreement’s term.
Procedural History
The plaintiff, Stettine, sued, arguing that the collective bargaining agreement was void due to Farnetti’s conflict of interest. Special Term ruled in favor of the plaintiff, declaring the contract void. The Appellate Division reversed, holding that CSEA was a voluntary nonprofit association exempt from the conflict-of-interest restrictions. The New York Court of Appeals then heard the case.
Issue(s)
Whether General Municipal Law § 802(1)(f), which exempts contracts with voluntary non-profit associations from conflict-of-interest rules, applies to a collective bargaining agreement negotiated by a municipal officer who had a direct financial interest in the outcome of the negotiations due to a local law linking his salary to the negotiated increases for union members?
Holding
No, because while CSEA is a voluntary non-profit association, the court declined to read the statute restrictively, and further, the legislative history did not indicate an intent to include only charitable or social welfare programs within the exception of General Municipal Law § 802(1)(f).
Court’s Reasoning
The Court reasoned that CSEA Suffolk qualified as a voluntary nonprofit association due to its relationship with CSEA, Inc., which had nonprofit status. Civil Service Law § 202 grants public employees the right to join or refrain from joining employee organizations, establishing the voluntary nature of CSEA. The Court rejected the argument that the exception should be limited to charitable organizations, finding no legislative intent to support such a narrow interpretation. The Court also noted that a prior opinion by Comptroller Levitt suggested that collective bargaining agreements were not