New York Law Review

Citizens for Alternatives to Animal Labs, Inc. v. Board of Trustees of the State University of New York, 87 N.Y.2d 357 (1995): Mandated Records and FOIL Disclosure

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Citizens for Alternatives to Animal Labs, Inc. v. Board of Trustees of the State University of New York, 87 N.Y.2d 357 (1995)

Records held by a state agency are subject to disclosure under the Freedom of Information Law (FOIL), regardless of whether they are maintained to comply with a federal mandate, unless a specific statutory exemption applies.

Summary

Citizens sought access to records held by SUNY regarding the source of animals used in research, as required by the federal Animal Welfare Act. SUNY denied the request, arguing it was not acting as a state agency when maintaining federally mandated records. The New York Court of Appeals reversed, holding that SUNY was an agency under FOIL, and the records were subject to disclosure because the function or purpose for which an agency’s documents are generated or held is not a basis for denying disclosure unless a specific statutory exemption applies. The case reinforces FOIL’s broad disclosure mandate.

Facts

SUNY’s Health Science Center at Brooklyn (SUNY HSC-B) conducts biomedical research using dogs and cats. The federal Animal Welfare Act requires dealers providing “random source” animals to research facilities like SUNY HSC-B to furnish certifications. These certifications contain data about the source of the animals, including the name and address of the provider. The Act aims to protect pet owners from theft by preventing the sale of stolen animals. Citizens for Alternatives to Animal Labs, Inc. requested access to these certifications under New York’s Freedom of Information Law (FOIL).

Procedural History

The Record Access Officer for SUNY HSC-B denied the FOIL request. Petitioners administratively appealed, but the denial was affirmed. Petitioners commenced a CPLR article 78 proceeding. Supreme Court granted the petition, directing SUNY to provide the requested documents. The Appellate Division reversed, holding SUNY HSC-B was not an “agency” under FOIL when maintaining records pursuant to federal mandate. The Court of Appeals granted leave to appeal.

Issue(s)

Whether SUNY HSC-B is an “agency” under Public Officers Law § 86(3) when maintaining random source certifications pursuant to a federal mandate, thus making those records subject to FOIL disclosure?

Holding

Yes, because SUNY HSC-B is an integral part of SUNY, which is an agency under FOIL, and the records were kept in connection with SUNY’s research mission, which constitutes a state governmental function. The purpose for which the certifications were kept (complying with a federal mandate) does not remove them from FOIL’s scope.

Court’s Reasoning

The Court of Appeals emphasized that SUNY is an “agency” under FOIL, and SUNY HSC-B is an integral part of SUNY. SUNY HSC-B was fulfilling SUNY’s mission to provide educational services and facilitate research, a State governmental function. The court rejected the Appellate Division’s rationale that complying with a federal mandate exempted the records from FOIL. The Court stated that “FOIL’S scope is not to be limited based on the purpose for which the document was produced or the function to which it relates.” Quoting from Capital Newspapers v. Whalen, 69 N.Y.2d 246, 252-253 (1987), the court emphasized that FOIL’s scope is not limited by the purpose for which a document was produced. The Court distinguished Matter of American Socy. for Prevention of Cruelty to Animals v Board of Trustees, 79 NY2d 927 (1992), noting that case concerned the Open Meetings Law and a committee whose powers derived solely from federal law, whereas SUNY HSC-B is part of a state agency performing a state function. The Court clarified that records kept by an “agency” are subject to disclosure unless a specific exception in Public Officers Law § 87(2) applies. Since respondents did not preserve any claim of a specific statutory exemption, the records were subject to disclosure. The Court emphasized the legislative goal of liberal disclosure under FOIL, limited only by narrowly defined exemptions. It noted the importance of transparency and accountability in government operations, which FOIL aims to promote.

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