Drew v. Schenectady County, 88 N.Y.2d 242 (1996)
Under Judiciary Law § 39(3)(a), a county must continue to furnish all goods, services, and facilities it provided to the courts prior to the Unified Court Budget Act of 1976, and this includes parking for court employees.
Summary
This case concerns whether Schenectady County was obligated to continue providing free parking to court employees after implementing new parking rules. Prior to the Unified Court Budget Act, the County provided free parking. The Court of Appeals held that under Judiciary Law § 39(3)(a), the County was obligated to continue providing such parking as it constituted a “facility” necessary for court operations. The court rejected the County’s argument that parking was a term of employment subject to different rules, emphasizing that the obligation arose from the County’s duty to maintain court facilities.
Facts
Prior to April 12, 1993, Schenectady County provided free parking to Unified Court System employees. To coincide with the completion of a jail on the sites formerly used for parking, the County implemented new rules that eliminated permit-designated spots for court employees, except for 13 County employees who were employed as of April 1, 1977. Unified Court System employees who lost their parking privileges commenced an action arguing the county violated Judiciary Law § 39.
Procedural History
The Supreme Court granted the petition, finding that the County’s new parking policy violated Judiciary Law § 39(3)(a). The Appellate Division affirmed. The County appealed to the Court of Appeals based on a two-Justice dissent at the Appellate Division.
Issue(s)
Whether the term “facilities” as used in Judiciary Law § 39(3)(a) includes parking for court employees, thereby obligating the County to continue providing free parking.
Holding
Yes, because the employee parking eliminated by the County in 1993 constitutes a court facility that the County was and is obligated to furnish pursuant to Judiciary Law § 39(3)(a).
Court’s Reasoning
The Court of Appeals determined that the plain language of Judiciary Law § 39 (3)(a) encompasses all court facilities used in the operation of the court, which includes parking. The Court relied on the principle that words of ordinary import in a statute are to be given their usual and commonly understood meaning. The Court noted, “[t]his provision was incorporated in the Unified Court Budget Act to ensure that even though the State assumed control of the court system’s budget, the localities retained responsibility for maintaining all court facilities in their jurisdictions which they previously financed and furnished.” The Court rejected the County’s argument that parking was a term and condition of employment under section 39(6)(a), stating that employee parking must be maintained because it comprises part of the court facilities the County is charged with operating under Judiciary Law § 39 (3)(a), not a contractual right of individual employees. The court stated, “[b]y providing such facilities, the County established its continuing obligation under Judiciary Law § 39 (3) (a) to provide the same type of parking facilities to all court employees”.