84 N.Y.2d 936 (1994)
An administrative agency’s interpretation of its own regulations will be upheld if it has a rational basis and is not unreasonable, arbitrary, or capricious.
Summary
This case concerns the definition of “eligibility date” within New York City’s Senior Citizen Rent Increase Exemption (SCRIE) program. The plaintiffs, a class of senior citizen tenants, argued that the eligibility date should be the earliest date an applicant met the SCRIE criteria, potentially years before applying. The New York City Department for the Aging interpreted it as the date before the most recent lease. The Court of Appeals upheld the Department’s interpretation, finding it rational and not arbitrary, as it avoids imposing retroactive rent recalculations on landlords for periods before an exemption application.
Facts
Plaintiffs were senior citizen tenants potentially eligible for SCRIE, which provides rent exemptions to low-income seniors in rent-stabilized housing. A dispute arose over the meaning of “eligibility date” in determining the base rent for the exemption. The Department for the Aging calculated the exemption based on the rent immediately preceding the most recent lease agreement, while the tenants claimed it should be based on the earliest date they met the eligibility criteria (age, income, and rent exceeding one-third of their income), even if that was before their current lease.
Procedural History
The Supreme Court initially granted the plaintiffs summary judgment. The Appellate Division modified this decision, denying the plaintiffs’ motion and granting the defendant’s cross-motion to dismiss the complaint, finding the agency’s interpretation rational. The Court of Appeals granted the plaintiffs leave to appeal.
Issue(s)
Whether the New York City Department for the Aging’s interpretation of “eligibility date” in the Senior Citizen Rent Increase Exemption program as the date prior to the latest lease is rational and not arbitrary or capricious.
Holding
No, because the Department’s interpretation has a rational basis and is not unreasonable, arbitrary, or capricious.
Court’s Reasoning
The Court of Appeals affirmed the Appellate Division’s ruling, deferring to the agency’s interpretation of its own regulation. The court emphasized that administrative regulations are upheld if they have a rational basis and are not unreasonable or arbitrary. Citing New York State Assn. of Counties v Axelrod, 78 NY2d 158, 166, the court noted that a challenger must show that a regulation “is so lacking in reason for its promulgation that it is essentially arbitrary.”
The court found the Department for the Aging’s interpretation rational because the tenants’ proposed interpretation would require landlords to retroactively adjust rents based on criteria potentially met years before any application for exemption. This would impose an unreasonable burden on landlords. As the court stated, plaintiffs’ argument “is fundamentally flawed as it would require the agency to impose on landlords rent reductions and recalculations for theoretically eligible persons, based on leases from a time preceding any application for the exemptions.”
There were no dissenting or concurring opinions. The court’s decision underscores the principle of judicial deference to administrative agencies in interpreting their own regulations, provided the interpretation is reasonable and consistent with the underlying statute.