County of Rensselaer v. Regan, 80 N.Y.2d 986 (1992)
The New York State Constitution prohibits the legislature from assigning administrative duties to the State Comptroller that are not incidental to the Comptroller’s constitutional functions.
Summary
Five counties and other plaintiffs challenged a provision in the 1990-1991 State Operations Budget that allowed the State Comptroller to withhold up to 2% of revenues collected by counties participating in the STOP-DWI program. These revenues were intended for local law enforcement and education efforts. The plaintiffs argued this provision violated Article V, § 1 of the New York Constitution, which limits the administrative duties the Legislature can assign to the Comptroller. The Court of Appeals affirmed the lower courts’ rulings, holding that the budget provision was unconstitutional because it assigned administrative duties to the Comptroller that were not incidental to the Comptroller’s constitutional functions. The Court found the counties had standing to bring the suit because the STOP-DWI legislation gave them a proprietary claim to the funds.
Facts
In 1981, New York established the STOP-DWI program, allowing counties to receive fines and forfeitures from alcohol-related driving offenses for local law enforcement and education. The 1990-1991 State Budget included a provision allowing the State Comptroller to “collect, withhold and receive” up to 2% of these revenues to cover the Commissioner of Motor Vehicles’ administrative costs for the STOP-DWI program.
Procedural History
The plaintiffs, including five counties, filed suit seeking a declaratory judgment that the budget provision violated the New York Constitution. The Supreme Court initially assumed, without deciding, that the plaintiffs had standing. The Appellate Division expressly held that the county plaintiffs had standing. Both the Supreme Court and the Appellate Division found the budget provision unconstitutional. The defendants appealed to the New York Court of Appeals.
Issue(s)
Whether the counties had standing to challenge the constitutionality of the legislative assignment of administrative duties to the Comptroller.
Whether the budget provision allowing the Comptroller to withhold a portion of the STOP-DWI revenues violated Article V, § 1 of the New York Constitution by assigning administrative duties to the Comptroller not incidental to the Comptroller’s constitutional functions.
Holding
Yes, the counties had standing because the STOP-DWI legislation granted them a proprietary claim to the fines and forfeitures, allowing them to challenge the legislature’s actions regarding those funds.
Yes, the budget provision violated Article V, § 1 of the New York Constitution because the legislature assigned to the Comptroller duties assertedly not incidental to his constitutional duties and granted overbroad discretion to effect the reduction.
Court’s Reasoning
The Court of Appeals determined that the counties had standing because the existing STOP-DWI legislation gave them a proprietary claim to the funds in question. Thus, they could challenge the legislature’s actions. The court found it unnecessary to consider the standing of the STOP-DWI coordinator or the association of coordinators. Turning to the merits, the Court acknowledged the legislature’s broad authority over the disposition of fines collected in the state. However, the plaintiffs challenged the methodology of reducing their share of revenues, specifically the assignment of administrative duties to the Comptroller that were not incidental to constitutional functions. The Court agreed with the lower courts’ reasoning, finding the budget provision unconstitutional as it violated Article V, § 1 of the State Constitution. The court emphasized that the legislature’s authority is not unlimited; it must conform its actions to the state constitution. The court quoted Hunter v. Pittsburgh, stating the State Legislature, so long as it “conform(s) its action to the state constitution, may do as it will” with regard to political subdivisions.