Judge Rotenberg Educ. Ctr. v. Maul, 91 N.Y.2d 301 (1998)
A social services district’s participation in New York State’s transitional care funding program for disabled young adults is voluntary, and therefore the district is not prohibited from withdrawing from the program.
Summary
Judge Rotenberg Educational Center sued to compel New York City to continue funding the care of eight severely disabled young adults placed at the Center by the City when they were children. The City withdrew from the State’s transitional care funding program, arguing that participation was optional under Social Services Law § 466. The New York Court of Appeals held that the City’s participation in the transitional care funding program is voluntary, based on the plain language of the statute and legislative history. The court affirmed the lower courts’ dismissal of the petition, finding the City could withdraw without following administrative procedures applicable to individual placement changes.
Facts
The Judge Rotenberg Educational Center, located in Rhode Island, provides residential schooling for severely disabled children. New York City had placed eight disabled children at the Center. These children “aged out” of the educational programs at age 21. New York State law requires localities to contract with out-of-state facilities when in-state facilities are not available. A transitional care funding program was created in 1982 to provide funding for these individuals until appropriate in-state adult care placements became available. The City participated in this program, with the State reimbursing 50% of the costs. In October 1994, the City announced its withdrawal from the transitional care funding program, citing the State’s primary responsibility for specialized care for mentally disabled adults. The City and State entered a memorandum of understanding in January 1995, where the City agreed to provide $1.116 million for transitional care until funds ran out, with explicit recognition that participation was optional. The funds were exhausted on May 31, 1995, and the City ceased funding.
Procedural History
The Judge Rotenberg Educational Center commenced a CPLR article 78 proceeding in Supreme Court to compel the City to continue payments. The Supreme Court dismissed the petition. The Appellate Division affirmed. The Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
Whether Social Services Law § 466 prohibits New York City from withdrawing from the State’s transitional care funding program for severely disabled young adults.
Holding
No, because Social Services Law § 466 makes participation in the transitional care funding program voluntary for social services districts, thus districts are not prohibited from withdrawing from the program.
Court’s Reasoning
The Court based its reasoning on the plain language of Social Services Law § 466 (2), which states that social services districts “may expend funds to provide transitional care.” The Court emphasized that “[i]t is fundamental that a court, in interpreting a statute, should attempt to effectuate the intent of the Legislature, and where the statutory language is clear and unambiguous, the court should construe it so as to give effect to the plain meaning of the words used.” The Court found that the legislative history supported the interpretation that the program was always intended to be voluntary. The Court cited the State Executive Department’s memorandum, noting that the Legislature was aware that some localities had already withdrawn from the program. The legislative response was to shift responsibility to the State, not to lock localities into the program. Regarding the petitioner’s argument about Social Services Law § 466 (5), the Court clarified that the administrative procedures outlined therein apply only when an individual is offered an appropriate in-state placement, and the individual’s procedural rights have been exhausted. Section 466(5) provides a mechanism to terminate payments by a participating locality; it does not define a substantive right to locally funded transitional care. The Court also emphasized Section 16 of chapter 600 of the Laws of 1994, which states that no provision of the act creates any right or entitlement for any individual to receive funds or services.