Town of Huntington v. New York State Division of Human Rights, 82 N.Y.2d 783 (1993)
The extraordinary writ of prohibition does not lie to prevent the Division of Human Rights from considering an individual’s complaint of racial discrimination when the Division has jurisdiction and the town has other adequate legal remedies.
Summary
The Town of Huntington sought a writ of prohibition to prevent the New York State Division of Human Rights from investigating a discrimination complaint filed by a former town employee, Reed. Reed, an African American, claimed he was discriminated against based on race. The Town argued that Reed’s discrimination claim was already litigated during a prior civil service proceeding regarding his termination and was therefore collaterally estopped. The Court of Appeals held that the writ of prohibition was inappropriate because the Division of Human Rights had jurisdiction over discrimination claims, and the Town had other adequate legal remedies to challenge the Division’s findings if necessary.
Facts
Charles Reed, an African American male, was hired by the Town of Huntington as a sign inspector. He was later suspended and charged with incompetence and misconduct. During a Civil Service Law § 75 hearing regarding his termination, Reed claimed the charges were racially motivated, alleging harassment and the use of racial epithets by his director. The Hearing Officer found Reed guilty of several charges but found no substantial evidence of racial discrimination. Reed was ultimately terminated. He then filed a complaint with the State Division of Human Rights, alleging discrimination in employment based on race.
Procedural History
Reed’s termination was initially challenged in a CPLR article 78 proceeding, which was initially successful but ultimately upheld on appeal after a review by a newly appointed Town official. Subsequently, Reed filed a complaint with the State Division of Human Rights. The Town then commenced its own article 78 proceeding, seeking a writ of prohibition to prevent the Division from investigating Reed’s complaint. The Supreme Court denied the Town’s request. The Appellate Division reversed, granting the petition and prohibiting the Division from considering Reed’s complaint, finding collateral estoppel. The Court of Appeals then reversed the Appellate Division’s decision.
Issue(s)
Whether the extraordinary writ of prohibition lies to prevent the New York State Division of Human Rights from considering an individual’s complaint of racial discrimination.
Holding
No, because the Division maintains jurisdiction to investigate claims of discrimination, and the Town failed to establish a “clear legal right” to the relief it seeks, having other adequate legal remedies available.
Court’s Reasoning
The Court of Appeals emphasized that a writ of prohibition is an extraordinary remedy used to prevent a body or officer from acting without or in excess of its jurisdiction. The Court noted that the Division of Human Rights has clear jurisdiction to investigate and rule on claims of discrimination under Executive Law § 295(6)(a). The Court found that the Town failed to demonstrate a clear legal right to the writ. The Court reasoned that the Town could challenge the Division’s findings on the merits after the investigation, if necessary, and therefore would not suffer irreparable harm by allowing the investigation to proceed. The court stated that prohibition “may be maintained solely to prevent or control a body or officer acting in a judicial or quasi-judicial capacity from proceeding or threatening to proceed without or in excess of its jurisdiction * * * and then only when the clear legal right to relief appears and, in the court’s discretion, the remedy is warranted”. The Court also highlighted that even if technically appropriate, the court must consider factors such as the gravity of potential harm and the availability of other remedies. Judge Levine took no part in the decision.